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UK Sanctions Update: OFSI Releases Financial Services Threat Assessment – Part 2

Last month, the UK’s Office of Financial Sanctions Implementation’s (“OFSI”) published a Threat Assessment analyzing sanctions compliance involving UK financial services firms since February 2022, when Russia invaded Ukraine. In the first of our two-part article (available here), we summarized the six key areas of risk that OFSI identified in its Threat Assessment. In this … Continue Reading

UK Sanctions Update: OFSI Releases Financial Services Threat Assessment – Part 1

In February 2025, the UK’s Office of Financial Sanctions Implementation (“OFSI”) issued a report outlining its assessment of the sanctions-related threats posed to the UK by firms operating in the UK’s financial services sector.  As to be expected, the report focuses on the risks associated with transactions since February 24, 2022, when Russia invaded Ukraine … Continue Reading

The EU suspends certain Sanctions on Syria to support Economic Stabilization, Political Transition, and Reconstruction

To encourage democratic development and achieve a peaceful and inclusive political transition, and to aid the swift reconstruction and economic recovery of the country and facilitate its eventual reincorporation into the global financial system, the European Council decided yesterday to suspend with immediate effect a number of sanctions and restrictive measures that had targeted key … Continue Reading

Trump Pauses FCPA Enforcement and Resets Priorities

On February 10, 2025, President Donald Trump issued an executive order titled, “Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security” (“FCPA EO”) that directs the Department of Justice (“DOJ”) to pause enforcement of the Foreign Corrupt Practices Act (15 U.S.C. 78dd-1 et seq.) (“FCPA”) for 180 days until new Attorney … Continue Reading

UK Sanctions Update: New OFSI Reporting Requirements for High Value Dealers and Art Market Participants

Late in 2024, the UK’s Office of Financial Sanctions Implementation (“OFSI”), the agency within His Majesty’s Treasury that is charged with the implementation of financial sanctions in the UK, introduced new sanction measures aimed generally at augmenting the operation and enforcement of UK financial sanctions and targeted specifically at High Value Dealers (“HVDs”) and Art … Continue Reading

EU Strengthens Sanctions Against Russia with 15th Package of Restrictive Measures

On December 16, 2024, the European Union (EU) adopted its 15th package of sanctions against Russia in response to its ongoing aggression toward Ukraine. The new measures target key sectors of Russia’s military-industrial complex, including the “shadow fleet” and companies that support this complex.  Our colleagues at The Trade Practitioner cover this significant development in … Continue Reading

OFAC Issues Additional Sanctions Guidance for the Maritime Shipping Industry

Failure to comply with the complex web of US sanctions laws and regulations carries significant risks both in terms of exposure to civil fines and penalties and reputational harm. To help maritime sector stakeholders navigate these regulations, the US Department of Treasury’s Office of Foreign Assets Control (OFAC) has published scenario-based sanctions compliance guidance on … Continue Reading

Fast-Growing UK Challenger Bank Fined £29m for Insufficient Sanctions and Financial Crime Controls

On September 27, 2024, the Financial Conduct Authority (“FCA”), which is a financial regulatory body in the UK that regulates firms providing financial services to consumers, fined a UK Challenger Bank (the “Bank”) £29 million due to significant failings in its financial sanctions compliance and anti-money laundering systems and controls. The FCA’s Summary of Reasons … Continue Reading

OFAC Guidance on the Statute of Limitations Extension

The President’s signing of the 21st Century Peace through Strength Act (the “Act”)[1] on April 24, 2024 marked one of the most significant expansions of the sanctions enforcement authority of the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”). For many decades OFAC’s civil enforcement actions have been limited to five years … Continue Reading

Recent DFSA Enforcement Activity and Future Priorities

In this article, we summarize the trends that have emerged from enforcement actions published between 2022 and the present day by the Dubai Financial Services Authority (the “DFSA”).… Continue Reading

The Chevron Reversal and Sanctions Litigation

With the recent SCOTUS decision overturning Chevron, lawyers involved in administrative litigation are considering how the decision will affect their matters.  Sanctions litigation is one area which will be impacted.  Now, when sanctions designations are challenged in court, the government will no longer be able to simply invoke Chevron deference and Specially Designated Nationals (“SDNs”) … Continue Reading

New 10-Year Statute of Limitations for U.S. Sanctions Violations

On April 24, 2024, President Biden signed into law H.R. 815[1], an emergency supplemental appropriations law, that provides $95.3 billion in military aid to U.S. allies and requires the divestiture of certain social media applications. While much of the discussion surrounding the new law focuses on the emergency foreign aid funding for Ukraine, Israel, and … Continue Reading

The Price Cap on Russian Oil – Part 2: Updated OFAC Guidance

In our previous article on this topic (which you can read here), we analyzed recent enforcement activity by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) related to the maritime transport of Russian-origin crude oil and Russian-origin petroleum products above price caps agreed by the “Price Cap Coalition,” comprising Australia, Canada, … Continue Reading

The Price Cap on Russian Oil – Part 1: Increased OFAC Enforcement

In June 2022, the Group of Seven (“G7”) countries—Canada, France, Germany, Italy, Japan, the United Kingdom, and the United States—decided to pursue a policy to cap the price of Russian oil. In December 2022, the G7 countries, joined by Australia and the supranational European Union (together, the “Price Cap Coalition”) officially implemented measures to ban … Continue Reading

The UAE Exits FATF’s Grey List

On February 23, 2024, the Financial Action Task Force (“FATF”) removed the United Arab Emirates (“UAE”) from its list of jurisdictions under increased monitoring (the “Grey List”).  As noted in our previous article (see here), FATF had intimated at its October 2023 Plenary that the UAE may be next off the Grey List as it … Continue Reading

Recent Changes to FATF’s “Grey List”; Could the UAE be Next Off the List?

Between October 25 and October 27, 2023, the Financial Action Task Force (“FATF”), an international policy-making and standard-setting body dedicated to combating money laundering and terrorist financing, held its third plenary meeting of the year (the “October Plenary”), at which it made important updates to its list of jurisdictions under increased monitoring, often externally referred … Continue Reading

U.S. Sanctions Review: A Recap of OFAC’s Recent Enforcement Actions (Second Half 2023)

The second half of 2023 saw eight enforcement actions from the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”).  These actions reflect a range of penalties, industries, sanctions programs, conduct, and lessons learned.  Below are some highlights from OFAC’s enforcement releases and settlement agreements. Penalties OFAC imposed a total of $984,851,289.90 in penalties … Continue Reading

United States Departments of Treasury, Commerce, and Justice Issue “Tri-Seal” Compliance Note on Voluntary Self-Disclosures of Potential Violations

Earlier this year, we published a post on the first Tri-Seal Compliance Note (“First Note”) issued by the United States Department of Justice’s (“DOJ”) National Security Division (“NSD”), the Department of Commerce’s Bureau of Industry and Security (“BIS”), and the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”).[1]  When issuing the First Note, … Continue Reading

Department of Justice Initiatives Prioritize Economic Sanctions Enforcement

On March 2, 2023, the Department of Justice announced several new initiatives that prioritize the investigation and enforcement of economic sanctions evasion, export control violations, and similar economic crimes.  Deputy Attorney General Lisa Monaco announced a “surge of resources to address a troubling trend: the intersection of corporate crime and national security.”  In particular, DOJ’s … Continue Reading

Congress Continues to Expand Bank Secrecy Act Whistleblower Program

The Consolidated Appropriations Act, 2023 amended the Bank Secrecy Act’s whistleblower provisions, setting a floor on the monetary award a whistleblower may receive, allowing whistleblowers to receive awards relating to successful enforcement of certain economic sanctions statutes such as the International Emergency Economic Powers Act, and establishing a fund from which to pay whistleblowers.  Following … Continue Reading

Increasing US Enforcement Action for Sanctions Violations by Crypto Exchanges Likely to Have Ripple Effect in UK and Europe

The investigation and enforcement of potential sanctions violations by crypto exchanges is an area of focus in the US at present.  The US Department of the Treasury’s Office of Foreign Assets Control’s (OFAC) recent settlement with Kraken, a global virtual currency exchange, is the most recent OFAC case demonstrating the risks for virtual currency platforms … Continue Reading

OFAC Announces Settlement with Virtual Currency Exchange Kraken

On November 28, 2022, the Office of Foreign Assets Control (“OFAC”) announced a settlement agreement with Payward, Inc., known as Kraken (“Kraken”), a United States-based virtual currency exchange. Kraken agreed to pay $362,158.70 to resolve its potential civil liability for 826 apparent violations of the Iranian Transactions and Sanctions Regulations (“Apparent Violations”). The settlement amount … Continue Reading

OFAC Sanctions Virtual Currency Mixer “Tornado Cash”

On August 8, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) sanctioned virtual currency mixer Tornado Cash for having laundered more than USD 7 billion worth of virtual currency since its founding in 2019.  This includes over USD 455 million worth of stolen virtual currency associated with the Lazarus Group, … Continue Reading

Russian Sanctions Update: Will “Biting” Eighth EU Sanctions Package Prohibit Legal Services?

“Russia should not benefit from European knowledge and expertise.”  That is the view of European Commission (“EC”) President Ursula von der Leyen, who recently proposed an eighth package of sanctions against Russia in response to “escalation” in Ukraine.  Among the “biting” new sanctions will be a wider ban on the provision of European services to … Continue Reading
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