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Until recently, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) and industry practice were generally aligned on the agency’s well‑known 50 Percent Rule: entities with less than…
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This article was last updated on October 7, 2026, but originally published on January 20, 2026. Many companies (and individuals) believe blocked vs rejected transactions mean the same thing for…
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In today’s interconnected financial and commercial systems, appearing on—or even being associated with—U.S. restricted party list (“RPL”) can lead to serious legal, financial, and reputational consequences. Whether you’re a foreign…
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Learn how foreign legal advisors can identify, assess, and manage U.S. sanctions and export control risks—covering OFAC, BIS, ITAR & risk mitigation strategies.
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Exactly a year ago, I published an article on our blog titled Banks Are Busy Verifying Client BIS Export Licenses. With the U.S. Department of Commerce’s Bureau of Industry and…
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Banks are increasingly verifying with their exporting clients whether their transactions related to the export of goods—even ordinary consumer goods—had appropriate license authorization from the U.S. Department of Commerce’s Bureau…
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Notwithstanding the robust economic sanctions imposed on Russia and Belarus since February 2022 by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), and export controls by…
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Many businesses are of the impression that as long as their internal trade compliance controls include screening against the U.S. Department of the Treasury’s Office of Foreign Assets Control’s (“OFAC”)…
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When creating or enhancing a U.S. economic sanctions compliance program, businesses will typically refer to certain published guidance from the U.S. Government that may include the U.S. Department of the…
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