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Inclusion on the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) Specially Designated Nationals and Blocked Persons (“SDN”) List is one of the most severe measures the…
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This article was last updated on October 7, 2026 with an Editor’s Note, but originally published on June 22, 2026. Editor’s Note: On July 7, 2026, following renewed hostilities, the…
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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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Receiving an OFAC administrative subpoena from the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is an unsettling event, especially if you are an individual or company…
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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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This article was last updated on October 7, 2026 with an Editor’s Note, but originally published on October 16, 2025, and previously updated on November 7, 2025. Editor’s Note: On…
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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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Tariffs have rarely been considered small talk — until 2025, when they became everyone’s problem. And for good reason. Since taking office on January 20, 2025, President Trump’s aggressive tariff…
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On October 7, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) confirmed some rather significant changes to the OFAC unblocking procedures for blocked property, which…
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One concern I hear a lot from businesses outside the United States is regarding so-called “secondary sanctions” of the United States (“U.S.”), especially since the rapid expansion of the U.S.…
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For better or worse, the U.S. Supreme Court has overruled Chevron v. Natural Resources Defense Council (“Chevron”), which for the last 40 years has provided many U.S. government agencies with significant…
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When President Biden signed into law the April 24, 2024 National Security Package (H.R. 815), media outlets predominately focused their coverage on the long awaited United States (“US”) aid for…
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