On September 21, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued an updated ransomware advisory (“Updated Advisory”) highlighting the sanctions risks associated with ransomware payments in connection with malicious cyber-enabled activities and the proactive steps companies can take to mitigate such risks, including actions that OFAC would consider to be “mitigating factors” in any related enforcement action. OFAC concurrently designated SUEX OTC, S.R.O. (“SUEX”) as a Specially Designated National (“SDN”), the first…
On August 11, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) and the Commerce Department’s Bureau of Industry and Security (“BIS”) issued a joint Fact Sheet: Supporting the Cuban People’s Right to Seek, Receive, and Impart Information through Safe and Secure Access to the Internet (the “Fact Sheet”) and a related press release. The Fact Sheet highlights the most relevant exemptions and authorizations pertinent to supporting the Cuban people through the provision of certain…
On June 8, 2021, President Biden signed Executive Order 14033 “Blocking Property and Suspending Entry Into the United States of Certain Persons Contributing to the Destabilizing Situation in the Western Balkans” (“EO 14033”), expanding the sanctions regime related to the Western Balkans. The White House also issued a fact sheet that details the US administration’s policy goals. US State Secretary Antony Blinken also issued a statement emphasizing the role that EO 14033 serves in modernizing…
On June 21, 2021, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued Belarus General License 3 (“GL 3”) authorizing certain transactions with the newly designated State Security Committee of the Republic of Belarus (“Belarusian KGB”) along with related FAQs (FAQ 912 and FAQ 913). In addition to the Belarusian KGB, OFAC designated 16 new parties to the Specially Designated Nationals and Blocked Persons List (“SDN List”) pursuant to Executive Order…