Sanctions

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For the first time, the Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) invoked the Fentanyl Sanctions Act and the Fend OFF Fentanyl Act on June 25, 2025, to issue three separate orders that each designate a Mexico-based financial institution as a “primary money laundering concern in connection with illicit opioid trafficking.” The three…

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…

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…

On May 23, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Syria General License (GL) No. 25 relaxing sanctions against the Government of Syria and twenty-eight (28) previously blocked Syrian entities and persons. GL 25 authorizes transactions that would otherwise be prohibited under the U.S. economic sanctions on Syria, including new investment…

On March 24, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela General License (GL) 41B extending the expiration date of Venezuela GL 41, which authorized certain transactions related to Chevron Corporation’s joint ventures in Venezuela.  Previously, under GL 41A issued earlier this month, all transactions “ordinarily incident and…

On March 6, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) 5R, “Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After July 3, 2025,” which continues to delay U.S. persons’ ability to enforce bondholder rights to the CITGO…

On March 4, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License 41A within its Venezuela-Related Sanctions Program: “Authorizing the Wind Down of Certain Transactions Related to Chevron Corporation’s Joint Ventures in Venezuela.” The Biden Administration had issued the precursor to General License (GL) 41A, GL 41…

On February 6, 2025, the State Department republished the “Cuba Restricted List” identifying entities and subentities that are under the control of, or act for or on behalf of, the Cuban military, intelligence, or security services or personnel. The Cuba Restricted List is significant because direct financial transactions with the enumerated entities and subentities are…

On February 4, 2025, President Donald Trump issued an Executive Order (EO) stating that Iran’s malign behavior and influence threaten the national interest of the United States and that it is “in the national interest to impose maximum pressure on the Iranian regime to end its nuclear threat, curtail its ballistic missile program, and stop…

UPDATE: On February 7, President Donald Trump issued an executive order (EO) addressing the additional duties placed on imports into the United States of products of China. The article below stated that use of duty-free de minimis treatment on imports for shipments under $800 was being removed for shipments from China. The president has since…