Wyatt Mince

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On April 3, 2023 the Office of Foreign Assets Control (“OFAC” or “the agency”) launched a new domain for its website at ofac.treasury.gov. This update aims to make it easier for users to navigate OFAC’s sanctions database, find industry guidance, utilize the reporting system, and stay current on policy updates. In particular, for guidance…

The Office of Foreign Assets Control (“OFAC”) recently announced a settlement agreement with Danfoss A/S (“Danfoss” or “the company”) in response to allegations that Danfoss directed its customers in Iran, Syria, and Sudan to make payments through third-party agents to Danfoss’s bank account at the branch of a U.S. financial institution located in the United…

On October 20, the Committee on Foreign Investment in the United States (CFIUS or the Committee) issued a press release laying out new guidance to provide clarity about how the Committee assesses violations of the laws and regulations that govern transaction parties, including potential breaches of CFIUS mitigation agreements.

Penalties are possible for the following…

On September 15, President Biden signed an Executive Order (EO) with the first ever formal Presidential direction to the Committee on Foreign Investment in the United States (CFIUS or the Committee). The EO emphasizes the risks that the Committee should consider when reviewing covered foreign company purchases of U.S. businesses. The EO is intended reemphasize…

On September 8, the U.S. Office of Foreign Assets Control (OFAC) extended a general license authorizing certain administrative transactions involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation. The new General License 13B authorizes U.S. persons and entities owned…

Yesterday, the White House issued a proclamation banning Russian-affiliated vessels from entering U.S. ports in response to Russia’s continued aggression in Ukraine, effective April 28, 2022. Banned vessels include Russian-flagged vessels, vessels owned by Russian persons, and vessels that are Russian operated. The order authorizes the U.S. Department of Homeland Security to issue regulations to…