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…