Last week, the Treasury Department’s Office of Foreign Assets Control (OFAC) announced a $5,228,298 settlement agreement with Sojitz (Hong Kong) Limited (Sojitz HK) for causing U.S. financial institutions to process U.S. dollar payments related to the purchase and resale of Iranian-origin goods in Asia. This case demonstrates how U.S. dollar payments often trigger OFAC jurisdiction
U.S. Expands Sanctions Targeting Chinese Technology Companies
Last week, the Treasury Department and Commerce Department imposed new sanctions on dozens of Chinese firms linked to the Chinese military.
Pursuant to Executive Order 13959, as amended by E.O. 14032, the Treasury Department’s Office of Foreign Assets Control (OFAC) sanctioned eight additional Chinese companies for operating as part of the Chinese Military-Industrial Complex
New Menu-Based Sanctions Target Facilitators of Global Drug Trade
On December 15, 2021, the Biden Administration issued a new Executive Order (E.O.) pursuant to the Fentanyl Sanctions Act (FSA) that modernizes the Treasury Department’s authority to impose sanctions on foreign drug traffickers and those that facilitate the international drug trade. The new sanctions are intended to address the flow of fentanyl, methamphetamines, and precursor
U.S. Imposes Additional Sanctions on Belarus: Sovereign Debt, Tourism, Defense, Potash, and Government Officials Targeted
On December 2, 2021, the Treasury Department’s Office of Foreign Assets Control (OFAC) expanded its Belarus-related sanctions program by imposing restrictions on dealings in Belarusian sovereign debt and adding 32 individuals and entities to its List of Specially Designated Nationals (SDN List). Among these additions are several state-owned or -controlled companies operating in the tourism,
OFAC Puts Virtual Currency Industry on Notice, Highlights Best Practices for Digital Commerce
On October 15, 2021, the Office of Foreign Assets Control (OFAC) issued an advisory providing sanctions compliance guidance for the virtual currency industry (Guidance). The Guidance follows a series of recent enforcement actions targeting the industry and the designation of a cryptocurrency exchange for facilitating ransomware payments. These developments highlight OFAC’s continued focus on this
Treasury Announces A More Tailored Approach to U.S. Sanctions Policy
Yesterday, the Biden Administration released the results of a broad review of U.S. economic sanctions policy following two decades of expanding use of sanctions as a foreign policy tool. The report recognizes that U.S. sanctions policy must evolve to confront changes to the global payments system, including the rise of digital currencies, reduced use of
New Authority to Impose Sanctions in Connection with Russian Energy Pipelines
On August 20, 2021, President Biden signed a new Executive Order to further implement sanctions provided under the Protecting Europe’s Energy Security Act (“PEESA”) of 2019. PEESA, which was enacted earlier this year, requires the State Department to issue a periodic report naming parties involved in the construction certain Russian energy export pipelines. Last week’s
U.S. Authorizes Broader Sanctions on Belarus, Targeting Government and Key Economic Sectors
Today, President Biden issued an Executive Order (E.O.) authorizing the imposition of additional sanctions on the Government of Belarus and a number of key sectors of the Belarusian economy in coordination with the United Kingdom and Canada, which also expanded sanctions on Belarus. The E.O. authorizes the Office of Foreign Assets Control (OFAC) to
OFAC Settlement with Payoneer Inc. Highlights Sanctions Expectations for Online Services
On July 23, 2021, the Office of Foreign Assets Control (“OFAC”) announced a settlement agreement with online money transmitter Payoneer Inc. (“Payoneer” or the “company”) for processing online transactions on behalf of persons in sanctioned jurisdictions and persons on OFAC’s Specially Designated Nationals (“SDN”) List. The case is the latest in a string of OFAC
U.S. Warns of Heightened Risk of Doing Business in Xinjiang
On July 13, 2021, the U.S. Departments of Commerce, State, Treasury, Commerce and Homeland Security and the Office of the U.S. Trade Representative issued an updated Advisory on supply-chain risks for U.S. businesses whose business activities may be implicated by human rights concerns related to forced labor in and outside of Xinjiang, China.
The updated