Sanctions

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In November 2024, the UK Government introduced regulations which granted its financial sanctions regulator – the Office of Financial Sanctions Implementation (“OFSI”) – greater intelligence gathering and enforcement powers. Our previous blog post on these amendments can be found here.

The changes included the extension of mandatory financial sanctions reporting obligations (“…

On May 23, 2025, the U.S. Departments of State (“State”) and the Treasury (“Treasury”) took actions that resulted in immediate sanctions relief for Syria. Specifically, Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License 25 (“GL 25”) pursuant to the Syrian Sanctions Regulations (“SySR”), the Weapons of Mass Destruction Proliferators Sanctions Regulations (“NPWMD”), the…

On January 6, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Syria General License 24, which authorizes transactions with governing institutions in Syria and certain activities related to energy and personal remittances. OFAC explained it issued General License 24 in light of the collapse of Bashar al-Assad’s government and…

On November 13, 2024, the U.S. Department of the Treasury’s (“Treasury’s”) Office of Foreign Assets Control (“OFAC”) updated its FAQs for insurers in a long-awaited move to modernize its published sanctions compliance guidance for the insurance industry.  None of the industry-specific FAQs had been updated since January 2015, and many had not been amended in…

On July 22, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) released guidance (“Guidance”) on how it will implement the new authority it was granted in the April 24, 2024 National Security Supplemental (“the Act”).  The Act extended the statute of limitations for civil, criminal, and forfeiture violations of sanctions…

An overview on new Russian sanctions and export controls issued by the U.S. (OFAC and BIS) and the UK focusing on the Russian financial, military, and LNG industries.

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The latest U.S. foreign aid bill supporting Ukraine, Israel, and Taiwan enacted on April 24, 2024 enhances U.S. sanctions and export controls including expanding (1) the statute of limitations for sanctions violations; (2) the President’s authority to coordinate sanctions efforts with the European Union and the United Kingdom; (3) sanctions and export controls on Iran…

On March 6, 2024, the Department of Commerce, the Department of the Treasury, and the Department of Justice published a Tri-Seal Compliance Note titled “Obligations of foreign-based persons to comply with U.S. sanctions and export control laws” (the “Note”). The Note stresses that U.S. persons are not the only entities subject to U.S. sanctions and…

Feb. 23, 2024–Today, following the death of opposition politician and anti-corruption activist Aleksey Navalny, and after two years of Russia’s unprovoked and unlawful full-scale invasion of Ukraine, the Commerce Department’s Bureau of Industry and Security (BIS) imposed additional export restrictions on 93 entities under 95 entries in Russia and seven other destinations. Sixty-three of the…

Earlier this week, the U.S. government partially re-implemented certain recently relaxed sanctions against Venezuela. According to a statement released by the United States Department of State on January 30th, the absence of meaningful progress in allowing candidates of the opposition Unitary Platform to stand for office in the upcoming Venezuelan presidential election has…