- SDN designations have immediate commercial
OFAC announces implementation of executive order providing for the revocation of Syria sanctions
As anticipated, on June 30, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced the implementation of President Trump’s Executive Order, “Providing for the Revocation of Syria Sanctions.” This action adds to General License 25 and removes the broad U.S. sanctions previously in place against Syria and the former regime
OFAC to amend Reporting, Procedures and Penalties Regulations
- Electronic filing and submission requirements: Filers will generally be required to use the electronic OFAC Reporting System (ORS) to submit (1)
Extended 10-year statute of limitations for sanctions enforcement
Although aid to Israel, Ukraine, and Taiwan made headlines last month when President Biden signed H.R. 815, the law also significantly expanded the scope of agencies’ enforcement authority under two key national security laws: the International Emergency Economic Powers Act (IEEPA) and the Trading with the Enemy Act (TWEA). Both now have 10-year civil
Shipping briefing: Drill, baby, drill? A new Venezuelan wave for the shipping industry
After many rumors of potential changes to the U.S. policy on Venezuela, on October 18, 2023 the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued four general licenses, representing a significant shift in its Venezuela sanctions program. Most pertinent for the shipping industry, certain sanctions that were in place against Petróleos de Venezuela, S.A. (PdVSA) and the Venezuela oil, gas and mining sectors have now largely been relaxed.Continue Reading Shipping briefing: Drill, baby, drill? A new Venezuelan wave for the shipping industry
Overview: U.S. eases Venezuela-related sanctions after election deal
After Venezuela’s government and its political opposition agreed on electoral guarantees for 2024 presidential elections, the Office of Foreign Assets Control (OFAC) issued four general licenses suspending select sanctions:
- General License 44 temporarily authorizes all transactions related to Venezuelan oil and gas sector operations, including producing, lifting, selling, and exporting oil or gas from Venezuela and new investment in oil or gas sector operations. The authorization includes transactions involving Petróleos de Venezuela, S.A. (PdVSA) or any entity in which PdVSA directly or indirectly owns a 50% or greater interest.
The license expires on April 18, 2024. OFAC will only renew the license if Maduro’s government follows through with its commitments and continues taking measurable steps toward democratic elections in 2024.
- General License 43 authorizes transactions involving CVG Compania General de Mineria de Venezuela CA (known as Minerven), the state-owned gold mining company.
- General License 3I and General License 9H remove the secondary market trading bans on buying certain Venezuelan sovereign bonds, as well as pre-2017 PdVSA bonds or equity.
Continue Reading Overview: U.S. eases Venezuela-related sanctions after election deal
New Tri-Seal Compliance Note highlights voluntary self-disclosure procedures and benefits
The U.S. Department of Justice (DOJ), Bureau of Industry and Security (BIS), and Office of Foreign Assets Control (OFAC) published their second Tri-Seal Compliance Note on July 26 summarizing their voluntary self-disclosure procedures for export control and sanctions violations. The Note highlights the potential benefits of self-disclosure, including significant mitigation of civil and criminal liability.
OFAC Alert: Potential Evasion of Russian Oil Price Cap
An alert was issued by the U.S. Office of Foreign Assets Control (OFAC) on April 17 warning about the potential evasion of the Russian-origin oil price cap. The alert came after OFAC had received reports that oil exported from the Eastern Siberia Pacific (ESPO) pipeline or ports on Russia’s eastern coast was trading above the
OFAC reaches a settlement with crypto platform following an investigation into sanctions violations
The U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) recently reached a settlement with a multi-asset trading platform where, to settle its potential civil liability for violations of sanctions against Iran, Cuba, and Venezuela, the crypto platform agreed to pay $72,230.
In a recent post, our team outlines the alleged sanctions violations and
New guidance on detecting sanctions evasion released by U.S. government
A Tri-Seal Compliance Note (“Note”) has been released by the Department of Commerce, Department of Treasury, and Department of Justice to assist businesses in identifying warning signs and implementing appropriate compliance measures to ensure cooperation with Russian-related sanctions and export controls. One of the most common sanction evasion tactics highlighted in the Note is the