On September 30, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published “Sanctions Compliance Guidance for Instant Payment Systems” (the “Guidance”). The Guidance underscores the importance of a risk-based approach to managing sanctions risks related to payment technologies such as instant payment systems. The availability of funds in real time poses a challenge for financial institutions that seek to comply with US sanctions regulations. OFAC recommends that developers of instant…
On September 15, 2022, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule (the “Final Rule”) to expand the existing sanctions against Russia and Belarus under the Export Administration Regulations (“EAR”). The purpose of the Final Rule is to “protect U.S. national security and foreign policy interests by further restricting Russia’s access to items that it needs to support its military capabilities.” The Final Rule took effect on September…
On September 2, 2022, the Group of 7 (“G7”) Finance Ministers issued a joint statement confirming their intention to implement a price cap for the purchase of Russian-origin crude oil and petroleum products. The statement says that G7 nations, along with other allies and partners, plan to prohibit the provision of services that enable maritime transportation of such products unless purchased at or below a price level determined by the coalition of countries adhering to…
On August 19, 2022, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) replaced existing General License (“GL”) 38 with GL 38A and issued a new GL 50. These GLs authorize certain activities otherwise prohibited by EO 14024, which targets, among other things, specific sectors (including the financial services sector) of the Russian economy. Our prior blog post regarding EO 14024 and the financial sanctions imposed thereunder can be found here, here, here,…