Sanctions

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On February 22, 2022, the Office of Foreign Assets Control (OFAC) expanded sanctions against Russia through blocking sanctions against two major Russian state-owned financial institutions, additional restrictions on Russian sovereign debt, sanctions on five Putin/Kremlin-connected elites, and the designation of several vessels. This follows the issuance of comprehensive sanctions on the territory recognized by Russia…

On February 21, 2022, in response to Russia’s recognition of the so-called Donetsk People’s Republic (DNR) and Luhansk People’s Republic (LNR) regions of Ukraine as “independent states,” President Biden issued Executive Order (EO) 14065 prohibiting certain transactions with respect to the DNR or LNR or such other regions of Ukraine (collectively, “Covered Regions”) as may…

On February 16, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) published in the Federal Register a final rule adding formal regulations to implement previously announced sanctions regarding Chinese Military-Industrial Complex companies. These formal regulations are the result of a November 12, 2020, Executive Order (EO) 13959 issued by former President…

Key Notes:

  • Several federal agencies recently released a business advisory emphasizing the heightened risk of doing business in Burma.
  • Four key areas of risk were identified: (1) state-owned enterprises (SOEs); (2) gems and precious metals; (3) real estate and construction projects; and (4) arms, military equipment, and related activities.
  • U.S. businesses with supply chains tied

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On February 2, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued new Frequently Asked Questions (FAQs) “designed to provide clarity” and further facilitate humanitarian aid and commercial activity in Afghanistan. These FAQs supplement and support the December 2021 Fact Sheet, Provision of Humanitarian Assistance to Afghanistan and Support for the…

The Department of the Treasury’s Office of Foreign Assets Control (OFAC) has announced its extension of two general licenses related to GAZ Group, Ukraine-related General License No. 13Q, “Authorizing Certain Transactions Necessary to Divest or Transfer Debt, Equity, or Other Holdings in GAZ Group” and Ukraine-related General License No. 15K, “Authorizing Certain Activities…

On December 16, 2021, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced it was placing another eight Chinese technology firms on its Non-SDN Chinese Military-Industrial Complex Companies List (CMIC List). This action was taken pursuant to Executive Order 13959 (as amended by Executive Order 14032), which prohibits U.S. persons from conducting…

On December 15, 2021, President Joseph Biden signed “Executive Order on Imposing Sanctions on Foreign Persons Involved in the Global Illicit Drug Trade,” an order finding that “the trafficking into the United States of illicit drugs, including fentanyl and other synthetic opioids, is causing the deaths of tens of thousands of Americans annually,…

On December 10, 2021, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned 15 individuals and 10 entities in several countries for their connection to human rights abuse and repression. In addition, OFAC imposed investment restrictions on one Chinese company in connection with the surveillance technology sector

In China, OFAC has placed…