We aim to provide timely updates and useful insights regarding OFAC sanctions and U.S. export controls actions.
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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…
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…
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,…
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…
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…
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…
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…
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…
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…
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…
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”)…
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…