On October 22, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) placed Russia’s two largest oil companies on its Specially Designated Nationals (SDN) List. This action was taken by the Treasury Department to “increase pressure on Russia’s energy sector and degrade the Kremlin’s ability to raise revenue for its war machine
Status of Trade-Related Agency Operations During Government Shutdown
As of October 1, 2025, federal funding lapsed for numerous U.S. government agencies, including those engaged in sanctions, export control, and customs compliance and enforcement. Due to the lack of funding, export licensing functions have been significantly curtailed. Below is an overview of the status of key operations at OFAC, DDTC, BIS, and CBP.
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…OFAC Again Extends Russia General License 13 Authorizing Transactions Ordinarily Incident and Necessary for Operations in Russia
On September 29, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) again extended previous Russia-related General License (GL) 13 by issuing a revised GL 13O, “Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024,” which states that U.S. persons are authorized to pay taxes, fees, or import…
OFAC Amends Remaining Syria-Related Sanctions Regulations
The Office of Foreign Assets Control (OFAC) issued a Final Rule effective September 25, 2025 amending the Syria-Related Sanctions Regulations at 31 C.F.R. Part 569. The heading of these regulations is being changed to the “Promoting Accountability for Assad and Regional Stabilization Sanctions Regulations.” These amended regulations further implement Syria-related Executive Order 14312 (June 30, 2025).
Annual Blocked Property Reports Due to OFAC by September 30
All persons subject to U.S. jurisdiction holding property blocked pursuant to various Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctions programs must file their Annual Report of Blocked Property (ARBP) by September 30, 2025. This does applies to all relevant persons, not only financial institutions.
This report is pursuant to 31 C.F.R.
OFAC Removes the Syrian Sanctions Regulations (codified at 31 C.F.R. Part 542)
On August 26, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) published a final rule in the Federal Register announcing it has removed the Syrian Sanctions Regulations and terminated the national emergency on which the regulations were based from the Code of Federal Regulations. Those regulations, codified at 31 C.F.R. Part…
OFAC Continues to Extend Russia General License 13 Authorizing Transactions Ordinarily Incident and Necessary for Operations in Russia
On July 8, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) again extended previous Russia-related General License (GL) 13 by issuing a revised GL 13N, “Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024,” which states that U.S. persons are authorized to pay taxes, fees, or import…
President Trump Announces Revocation of Syria Sanctions and Waiver of Other Sanctions and Export Controls
On June 30, 2025, President Donald Trump issued an Executive Order (EO) that removes sanctions on Syria, provides for the issuance of waivers that will permit the relaxation of export controls and other restrictions on Syria, and otherwise seeks to support “the positive actions” taken by the new Syrian government under President Ahmed al-Sharaa. The…
OFAC Amends Russia General License 55 Relating to the Sakhalin-2 Oil and Gas Project
On June 18, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Russia-related General License (GL) 55D, “Authorizing Certain Services Related to Sakhalin-2.” This general license authorizes certain services that would otherwise be prohibited under OFAC’s Russia sanctions program related to Sakhalin-2 involving the maritime transport of crude oil originating from…
OFAC Again Continues to Extend Authorizations Under Russia General License 13
On April 7, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) again extended previous Russia-related General License (GL) 13 by issuing a revised GL 13M, “Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024,” which states that U.S. persons are authorized to pay taxes, fees, or import…
