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OFAC

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Accounting, Trust and Corporate Formation, and Management Consulting Services Ban On May 8, 2022, the US Department of Treasury’s Office of Foreign Assets Control (“OFAC”), in consultation with the US Department of State, issued a Determination Pursuant to Section 1(a)(ii) of Executive Order 14071 (“EO 14071 Determination”) determining that the prohibitions under Section (1)(a)(ii) of Executive Order (“EO”) 14071 (our previous blog regarding EO 14071 can be found here) shall apply to accounting, trust and…

On May 2 and 5, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued three new and two amended Russia-related General Licenses (“GLs”). OFAC also issued one new Frequently Asked Question (“FAQ”) and amended another. Additionally, Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a tranche of Russia-related FAQs. New General Licenses GL 30 authorizes all transactions involving Gazprom Germania GmbH that are prohibited by Directive 3 under…

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 April 25, 2022, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) re-issued General License 13R (“GL 13R”) and General License 15L (“GL 15L”), narrowing those authorized activities with GAZ Group and entities owned 50% or more by GAZ Group (“GAZ”), as further described below. OFAC also issued a set of updated FAQs to clarify the scope of authorized activities under these GLs. Our most recent blog post on these GLs is available…