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
U.S. Adds 34 Technology Companies to Entity List
Yesterday, the Bureau of Industry and Security (BIS) of the U.S. Department of Commerce added 14 companies based in China and 20 companies located elsewhere to the U.S. Entity List. According to BIS, the Chinese companies are involved in China’s “campaign of repression, mass detention and high-technology surveillance” against Uyghur and other minorities in Xinjiang.
U.S. Expands Sanctions on Belarus
Yesterday, the U.S. Office of Foreign Assets Control (OFAC) sanctioned several Belarusian individuals and entities, including the State Security Committee of the Republic of Belarus (the Belarusian KGB), in response to the Lukashenka regime’s escalating violence and repression. (The full list of changes to the Specially Designated Nationals (SDN) and Blocked Persons List is available
Department of Commerce Removes UAE from Boycott List
Last week, the U.S. Department of Commerce removed the United Arab Emirates (“UAE”) from its list of countries boycotting Israel in response to the formal termination of the UAE’s participation in the Arab League boycott of Israel.
Under Commerce’s updated rules, a request for information, action, or agreement from the UAE made after August 16,
New E.O. Revokes TikTok and WeChat Prohibitions, But Lays Framework for New Restrictions
Yesterday, President Biden signed an Executive Order (“E.O.”) that formally revokes and replaces three earlier E.O.s that aimed to restrict transactions with TikTok, WeChat, and other communications and Fintech applications and provides a new framework to address security concerns related to the information and communications technology and services (“ICTS”) supply chain. The new E.O. was