Tag Archives: OFAC

Trump Administration Considering Using IEEPA to Block Chinese Acquisitions

According to Bloomberg, the Trump administration is considering using the International Emergency Economic Powers Act (IEEPA) to block Chinese investments in industries or technologies “deemed important” to the U.S.  (This statute has been used primarily to authorize economic sanctions and embargoes administered by the Office of Foreign Assets Control).  To utilize IEEPA, the President must … Continue Reading

Trump makes it official: Venezuelan digital currency is subject to sanctions

The President signed a new Executive Order today making it unlawful to engage in transactions involving digital currency issued by the Venezuelan government.  The Executive Order makes official prior guidance from the Office of Foreign Assets Control (OFAC), which stated that dealings related to Venezuelan digital currency would likely be prohibited under existing sanctions. Last … Continue Reading

New North Korea Sanctions Regulations Become Effective Today

The Office of Foreign Assets Control (OFAC)’s new North Korea Sanctions Regulations become effective today.  In addition to making certain technical and conforming changes, the newly updated Part 510 incorporates recent changes to the sanctions program under Executive Orders (E.O.) 13687, 13722, and 13810, the North Korea Sanctions and Policy Enhancement Act of 2016, and … Continue Reading

U.S. Issues New North Korea Sanctions and a Warning to the Global Shipping and Finance Industries

Today the U.S. Office of Foreign Assets Control (OFAC) issued new sanctions targeting the shipping industry for dealings involving North Korea.  The sanctions include the designation of 56 companies and vessels involved in conducting illegal trade with North Korea. OFAC also issued new guidance for the global shipping and finance industries, describing common methods used … Continue Reading

Trump Administration Declines to Issue Sanctions Related to Russia’s Military and Intelligence Sectors

Under Section 231 of the Countering America’s Adversaries Through Sanctions Act (CAATSA), the Trump administration was due to issue secondary sanctions on non-U.S. persons that conduct significant transactions with Russia’s defense and intelligence sectors.  The Trump administration declined to issue those new sanctions, claiming that CAATSA was serving as an effective deterrent – discouraging non-U.S. … Continue Reading

New OFAC designations signal continued U.S. sanctions pressure on Russia

Last week, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) blacklisted 21 individuals and nine entities for various reasons, including involvement in the ongoing conflict in eastern Ukraine, connections to the Crimea region (which is subject to a complete U.S. embargo), and links to the Russian government.  Several of the newly … Continue Reading

U.S. Implements Global Magnitsky Sanctions Targeting Corruption and Human Rights Abuses Worldwide

On December 20, 2017, the President issued Executive Order 13818 implementing new sanctions against human rights abusers and persons involved in corruption pursuant to the Global Magnitsky Human Rights Accountability Act (Global Magnitsky Act).  The Global Magnitsky Act allows the U.S. government to target persons and entities involved in gross human rights abuses – such … Continue Reading

U.S. Issues Enhanced Sanctions on Russian Energy Sector

As required under recent sanctions legislation, the U.S. Office of Foreign Assets Control (OFAC) recently issued an updated Directive 4 that will expand sectoral sanctions on the Russian energy industry. The new rules, which apply to projects initiated on or after January 29, 2018, will bar persons subject to U.S. jurisdiction from providing goods, services, or … Continue Reading

OFAC Extends Sanctions Relief for Belarussian Conglomerates

Today the Office Foreign Assets Control (OFAC) extended sanctions relief for nine Belarussian conglomerates, including Belneftekhim. OFAC has authorized transactions with the listed Belarussian Specially Designated Nationals (SDNs) since October 2015 through a series of temporary general licenses. Today’s General License No. 2D extends the sanctions relief through April 30, 2018, subject to the restrictions … Continue Reading

The Paper Caper: U.S. Persons Cannot Help Foreign Subsidiaries or Affiliates with Sanctioned Country Transactions

A recent settlement agreement between the Office of Foreign Asset Control (OFAC) and BD White Birch Investment LLC, a U.S.-based paper company, is an important reminder that U.S. companies cannot assist their foreign subsidiaries or affiliates with sales related to sanctioned countries. … Continue Reading

New U.S. Sanctions on North Korea – What You Need To Know

Last week the U.S. government announced new sanctions on North Korea designed to target non-U.S. persons, aircraft, vessels, and financial institutions that facilitate trade and transactions with the country.  The Executive Order contained four elements: new authority to designate persons as Specially Designated Nationals (SDNs), sanctions on certain aircraft and vessels that visit North Korea, … Continue Reading

U.S. Hits Venezuela and Petróleos de Venezuela (PdVSA) with Financial Sanctions

On Friday, August 25th, the U.S. government announced new financial sanctions on Venezuela.  The move is the most recent U.S. response to the escalating political and humanitarian crisis in the country.  The new Executive Order bars U.S. persons from: Dealing in ‘new debt’ of Petróleos de Venezuela (PdVSA), Venezuela’s state-owned oil company, that has a … Continue Reading

U.S. Targets Chinese and Russians for North Korea Dealings

The Office of Foreign Assets Control (OFAC) designated 16 parties as Specially Designated Nationals (SDNs) today, effectively seizing their assets in the United States, blocking them from doing business with U.S. parties, and denying them access to the U.S. financial system.  The designations mark the latest escalation of sanctions on North Korea and an increasing … Continue Reading

OFAC Penalizes Singaporean Communications Provider $12 Million For Iranian Transactions Conducted In U.S. Dollars  

Global communications solutions provider, CSE TransTel, a subsidiary of CSE Global Limited (both based in Singapore), recently agreed to settle Iran sanctions charges leveled by the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) for $12 million.  The charges involve 104 violations of the Iran sanctions between June 2012 and March 2013.  The case … Continue Reading

U.S. Blacklists the President of Venezuela as a Specially Designated National (SDN)

Today the U.S. Office of Foreign Assets Control (OFAC) took the unusual step of blacklisting the leader of a foreign country as a Specially Designated National (SDN).  OFAC added Nicolas Maduro, the President of Venezuela, to the SDN List after a flawed vote that essentially replaced the country’s democratically elected legislature with a new body … Continue Reading

President Punts on Sudan Sanctions

The President issued a new Executive Order today delaying a decision on whether to permanently lift sanctions on Sudan. In January, President Obama announced the interim lifting of U.S. sanctions on Sudan.  At that time the Office of Foreign Assets Control (OFAC), the agency primarily responsible for implementing U.S. sanctions, issued a general license (or … Continue Reading

Trump Issues New Cuba Restrictions

Late last week, President Trump issued a directive that would purportedly “cancel” the recent changes in the Cuban Assets Control Regulations made under President Obama’s administration.  This announcement caused confusion in the business community, which had relied on the Obama administration’s changes to begin commercial engagement in Cuba.  Even though the directive actually leaves many … Continue Reading

California Court Orders TransUnion to Pay Record $60M for FCRA Violations for Erroneously Linking Consumers to Criminals in OFAC Database

A California jury in federal court ruled on Tuesday, June 20, that TransUnion violated the Fair Credit Reporting Act (FCRA) by erroneously linking certain consumers with similarly named terrorists and criminals in the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC’s) database.  The jury awarded statutory and punitive damages in excess of $60 million, … Continue Reading

Appeals Court Says That Actual Arrival In Iran Is Not Necessary For OFAC To Find Violation

On May 26, the U.S. Court of Appeals for the DC Circuit remanded for further consideration OFAC’s imposition of a $4 million penalty against Epsilon Electronics for 39 shipments found to violate the Iranian Transactions and Sanctions Regulations (“ITSR”).  According to the DC Circuit, OFAC failed to meet its burden to justify its finding of … Continue Reading
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