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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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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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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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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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On March 21, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) significantly expanded its end-user restrictions under the Export Administration Regulations (“EAR”), 15 C.F.R. Part 744,…
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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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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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