Export Controls and Sanctions

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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…

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…

Last Friday, the Office of Foreign Assets Control issued two general licenses aimed at facilitating humanitarian assistance and the provision of essential supplies to the people of Afghanistan.  Subject to exceptions, the general licenses establish blanket authorizations for transactions involving the Taliban or the Haqqani Network (and entities directly or indirectly owned by the same)…

Last week, the Biden administration issued a new Executive Order (“E.O.”) that authorizes “menu-based” sanctions on persons determined to be responsible for or complicit in the ongoing crisis in northern Ethiopia, and announced a policy of denial for export licenses of military equipment to Ethiopia.  The two actions are aimed to stop the escalating conflict…

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…

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…

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…

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…

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. …

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…