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Terence Gilroy

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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…

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…

On November 26, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) published a final rule amending the Syrian Sanctions Regulations (“Final Rule”). The Final Rule expands the existing general license at § 542.516 (the “General License”) to authorize nongovernmental organizations (“NGOs”) to engage in certain assistance-related investment activities in support of not-for-profit activities in Syria. The General License authorizes NGOs to export/reexport services to Syria in support of not-for-profit activities in Syria, i.e., humanitarian projects…

On November 10, 2021, the US Departments of State, Treasury, and Commerce issued a joint advisory (the “Advisory”) cautioning US companies operating in or considering operations in Cambodia to be conscious of dealings with entities and in sectors potentially involved in human rights abuses, criminal activities, and corrupt business practices. We describe the Advisory in additional detail below. On the same day the Advisory was issued, the Treasury Department’s Office of Foreign Assets Control (“OFAC”)…