On March 14, 2024, the U.S. Department of Stateās Directorate of Defense Trade Controls (āDDTCā) and the U.S. Department of Commerceās Bureau of Industry and Security (āBISā) announced more restrictive export controls on Nicaragua stated to be in response to the Nicaraguan Governmentās human rights abuses, attacks on civil society, and increased cooperation with Russia. The DDTC and BIS press releases are available here and here. DDTC: New ITAR Export Controls The State Department announced…
On January 25, 2023, the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued an alert to financial institutions regarding potential investments in the US commercial real estate (“CRE”) sector by sanctioned Russian individuals, their family members, and entities through which they act (“Alert”). The Alert complements an earlier alert that FinCEN issued in March 2022, shortly after Russia invaded Ukraine. Our coverage of the March 2022 alert can be found here. In…
On December 15, 2022, the United States Department of the Treasury’s Office of Foreign Assets Control (āOFACā) added Public Joint Stock Company Rosbank (āRosbankā) and 17 subsidiaries of VTB Bank Public Joint Stock Company (“VTB Bank”) to the Specially Designated Nationals and Blocked Persons List (āSDN Listā). The United States Department of State (āState Departmentā) designated Vladimir Potanin, three members of his family, and his company Interros, pursuant to Executive Order 14024, with the result…
On April 28, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued a final rule amending and reissuing the Somalia Sanctions Regulations, 31 C.F.R. Part 551 (“Regulations”) to further implement two existing Executive Orders, Executive Order 13536 of April 2010 and Executive Order 13620 of July 2012, and to replace the prior Somalia Sanctions Regulations that were published in May 2010 in abbreviated form. The Regulations also add a number of definitions…