On February 23, 2022, as “another piece of [the US government’s] initial tranche of sanctions in response to Russia’s actions in Ukraine,” the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) designated Nord Stream 2 AG, the Swiss company in charge of building Russia’s Nord Stream 2 gas pipeline, and its German chief executive officer, Matthias Warnig, to OFAC’s List of Specially Designated Nationals and Blocked Persons. The sanctions on Nord Stream 2 follow…
The US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued a final rule amending and reissuing the Transnational Criminal Organizations Sanctions Regulations, 31 C.F.R. 590 (“TCOSR”) to further implement two existing Executive Orders (“EO”) related to transnational criminal organizations, EO 13581 of July 24, 2011, “Blocking Property of Transnational Criminal Organizations,” and EO 13863 of March 15, 2019, “Taking Additional Steps to Address the National Emergency With Respect to Significant Transnational Criminal Organizations.” The…
In December 2021, the US Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued four General Licenses (“GLs”) (GLs 16, 17, 18, and 19), published seven new Frequently Asked Questions (“FAQs”) (FAQs 949, 950, 951, 952, 953, 954, and 955), and amended three FAQs (FAQs 929, 930, and 931), which address primarily authorized humanitarian activities related to Afghanistan OFAC also issued a Fact Sheet titled “Provision of Humanitarian Assistance to Afghanistan and Support for…
In November 2021, the State Department’s Directorate of Defense Trade Controls (“DDTC”) issued new and updated FAQs on violations, disclosures, debarments, rescissions, and reinstatements under the International Traffic in Arms Regulations (“ITAR”). The FAQs mostly reiterate and further clarify past guidance from DDTC on related matters. Key issues are summarized below. For further details, we recommend visiting the DDTC website (here and here) for the full texts of the FAQs. Whether disclosure is required: A…