On September 13, 2024, the United States designated and placed on the Department of the Treasury’s Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) List three entities and two individuals for their connection to Russia’s destabilizing actions abroad, particularly efforts to undermine and manipulate the outcome of the October 2024 Moldovan presidential election.
Sanctions
OFAC Issues Final Rule on Procedures Related to Blocking Property
The Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a final rule on Updating Provisions Related to Blocking and Other Actions Related to Specific Property or Interests in Property. The rule is effective as of September 17, 2024.
The new rule aims to clarify OFAC’s process for issuing orders that block…
Annual Blocked Property Reports Due to OFAC by September 30
All U.S. persons and persons otherwise subject to U.S. jurisdiction, not only U.S. financial institutions, 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, 2024.
This report is pursuant to 31 C.F.R. §§ 501.603…
OFAC Publishes Interim Final Rule Extending Recordkeeping Requirement to 10 Years
On September 11, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) published an Interim Final Rule to amend its Reporting, Procedures and Penalties Regulations under 31 C.F.R. Part 501, which extends recordkeeping requirements for certain transactions from 5 years to 10 years. This Interim Final Rule takes effect on March 12…
OFAC Issues Revised Russia Telecommunications General Licenses and an Alert on Russian Attempts to Evade Sanctions
On September 4, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a revised Russia General License (GL) 25E that continues to authorize all transactions ordinarily incident and necessary to the receipt or transmission of telecommunications involving the Russian Federation. This continues to allow for services incident to the exchange of…
On the Eve of Ukrainian Independence Day, the United States Expands Export Controls and Sanctions on Russia and Belarus
On August 23, 2024—one day before Ukrainian Independence Day—the Department of Commerce’s Bureau of Industry and Security (BIS), the Department of the Treasury, and the Department of State commemorated the milestone by expanding U.S. export controls and sanctions on Russia and Belarus. Notably, the agencies’ actions also come amidst Ukraine’s surprise incursion into Russia’s Kursk…
OFAC and BIS Significantly Extend Sanctions and Export Control Restrictions Against Russia and Belarus
Key Notes:
Commerce and Treasury Departments Announce New Sanctions and Export Control Restrictions on Russia and Belarus
On June 12, 2024, the Office of Foreign Assets Control (OFAC) and the Bureau of Industry and Security (BIS) announced new sanctions and export control restrictions on Russia and Belarus. These measures have significant implications for companies that do business with or in these regions, as they may face new licensing requirements, limitations, or prohibitions…
U.S. Aid Package for Ukraine, Israel and the Indo-Pacific Incorporates Extensive Sanctions and Export Control Reforms
On April 24, 2024, President Biden signed into law a broad national security package which included the Israel Security Supplemental Appropriations Act, 2024; Ukraine Security Supplemental Appropriations Act, 2024; Indo-Pacific Security Supplemental Appropriations Act, 2024; 21st Century Peace through Strength Act; FEND off Fentanyl Act; and the Rebuilding Economic Prosperity and Opportunity for Ukrainians Act.
New Legislation Extends U.S. Sanctions Enforcement Period to Ten Years
On April 24, 2024, President Biden signed into law a significant amendment to the statute of limitations for violations under U.S. sanctions laws, as part of the national security package (H.R. 815). This change extends the period for enforcement actions from five to ten years, reflecting a more robust approach to national security…