On April 29, 2022 the US Department of Treasury’s Office of Foreign Assets Control (“OFAC”) announced the publication of a Final Rule that reissued and renamed the Ukraine-/Russia-Related Sanctions Regulations (“Reissued Regulations”) and updates to related public guidance. Found at 31 C.F.R. Part 589, the Reissued Regulations took effect on May 2 and have been expanded to include a more comprehensive set of regulations, including additional interpretive and definitional guidance, general licenses, and other regulatory…
On March 24, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued two new and two reissued General Licenses and issued new and revised Frequently Asked Questions (FAQs). OFAC also added more than 400 parties to the Specially Designated Nationals and Blocked Persons List (“SDN List”). A summary of these developments can be found on OFAC’s Recent Actions page here and here. New and Revised General Licenses OFAC issued two…
On March 7, 2022, the US Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued an alert to financial institutions warning about potential attempts to evade US sanctions and other restrictions imposed on Russia and Belarus (“Alert”). The Alert includes red flags that financial institutions should review to help identify potential attempts to avoid sanctions, with a particular focus on convertible virtual currency (“CVC”), and also reminds companies of their reporting obligations under the Bank Secrecy…
On February 24, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued additional expansive sanctions on Russia in response to Russia’s further invasion of Ukraine (these sanctions are in addition to the significant export controls on Russia implemented by the US Commerce Department’s Bureau of Industry & Security on February 24, 2022, which are discussed in a separate blog post, here). A press release (“Russia-Related Press Release”) from the US…