On October 15, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) published sanctions compliance guidance for the virtual currency industry (the “Guidance”), given that “the growing prevalence of virtual currency … brings greater exposure to sanctions risk.” This Guidance follows (1) the recent and first-ever designation of a virtual currency exchange (SUEX OTC, S.R.O) by the OFAC (see our recent post on this here), and (2) the launch of the National Cryptocurrency Enforcement…
On August 9, 2021, the United States, the United Kingdom, and Canada significantly escalated sanctions against Belarus in a multilateral effort to put pressure on the current Lukashenko regime. These sanctions were announced on the first anniversary of the fraudulent elections held in Belarus on August 9, 2020 and follow a series of previous measures against Belarus, including most recently the coordinated measures between the UK, US, Canada and the EU in June (see our…
On April 12, 2021, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued four amended Frequently Asked Questions (“FAQs”) related to submissions made pursuant to the Trade Sanctions Reform and Export Enhancement Act of 2000 (“TSRA”), as well as the Sudan Program and Darfur Sanctions. We summarize these FAQs below. FAQs Concerning TSRA FAQs 97 and 98 clarify the process for obtaining a TSRA license, as follows: FAQ 97 provides…
The US Treasury Department’s Office of Foreign Assets Control (“OFAC”), the US State Department (“State”), and the US Commerce Department (“Commerce”) issued rules adjusting maximum civil monetary penalties (“CMPs”) under the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015 (“FCA”), as outlined below. (For additional years of CMPs, see our previous blog post available here.) OFAC CMP Adjustments Under OFAC’s final rule published on March 17, 2021, the adjusted penalties apply to CMPs…