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The U.S. Department of the Treasury’s Office of Foreign Assets Control’s (“OFAC”) last civil enforcement action for 2023 involved insurance company Privilege Underwriters Reciprocal Exchange (“PURE”), and was a stark reminder of…
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On the eve of the second anniversary of Russia’s full-scale war against Ukraine, February 23, 2024, and also in response to the on February 16, 2024 death of opposition figure…
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Economic sanctions, especially those related to Russia and Iran, routinely make news headlines. However, the underlying legal changes that occur can significantly impact the operations of organizations engaging in cross-border…
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The expansive scope of United States economic sanctions programs—comprised of the laws and regulations administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”)—can have a…
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This article was last updated on October 7, 2026 with an Editor’s Note, but originally published on October 24, 2023. Editor’s Note: On August 24, 2026, the Trump Administration launched…
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With everything going on in the world these days, one could excuse the media’s apparent disinterest in an otherwise significant change in U.S. economic sanctions policy towards Venezuela, which occurred…
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In many instances where I’ve been called upon to evaluate a business’s trade compliance program, I notice that company policy is to prohibit any and all dealings with Sudan. It…
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As of March 27, 2023, the Russian Federation requires all western businesses seeking to divest from the country to make a direct donation to the Russian state. This leaves western…
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The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) is specifically targeting businesses and individuals involved in the provision of jet fuel to Burma’s (a.k.a. Myanmar) military…
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With one full year gone by since Russia invaded Ukraine, a lot has been written in the history books of U.S. economic sanctions and export controls. Marking this first anniversary,…
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