On January 14, 2025, President Biden took action towards rescinding Cuba’s designation as a State Sponsor of Terrorism (“SST”) and to remove restrictions on financial transactions with certain Cuban parties by issuing to Congress a Certification of Rescission of Cuba’s Designation as a State Sponsor of Terrorism (“Certification”) and National Security Memorandum 29 (“NSM-29”) revoking a past National Security Presidential Memorandum related to Cuba that had been issued by then-President Trump in June 2017. President…
Shortly after taking the oath of office today, newly inaugurated President Trump signed a flurry of Executive Orders (“EOs”) and other executive actions. This include several actions related to US sanctions and export controls. Authority to Designate Cartels as Foreign Terrorist Organizations or Specially Designated Global Terrorists Trump signed an EO Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists. This EO creates a legal authority to designate certain international…
The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), the US Department of State (“State”), the US Department of Commerce (“Commerce”), and the US Department of Energy (“DOE”) issued rules adjusting maximum civil monetary penalties (“CMPs”) under the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015, as outlined below. (For additional years of CMPs, see our previous blog post available here.) OFAC CMP Adjustments Under OFAC’s final rule issued on January 15, 2025,…
On October 30, 2024, the US Government imposed sanctions on hundreds of entities and individuals across the globe, primarily in response to Russia’s continued war in Ukraine, and amended US export controls related to Russia and Belarus. Below, we describe the key actions taken by the US Departments of the Treasury, State, and Commerce. 1. OFAC Actions With the aim of disrupting global sanctions evasion networks and domestic suppliers to Russia’s military-industrial base, the US…