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OFAC

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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…

On April 28, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued a final rule amending and reissuing the Somalia Sanctions Regulations, 31 C.F.R. Part 551 (“Regulations”) to further implement two existing Executive Orders, Executive Order 13536 of April 2010 and Executive Order 13620 of July 2012, and to replace the prior Somalia Sanctions Regulations that were published in May 2010 in abbreviated form. The Regulations also add a number of definitions…

On April 19, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) revoked Belarus General License 2G (“GL 2G”), which had generally authorized US Person participation in transactions involving nine Belarusian state-owned entities designated as Specially Designated Nations (“SDNs”), and entities in which they own a 50 percent or greater interest. The revocation of GL 2G effectively strengthens US sanctions against Belarus, and may make it more difficult for US Persons to conduct…

In the past several days, the US Government has issued a slew of sanctions measures targeting Russia. These represent the first major escalation of sanctions against Russia under the Biden Administration and, according to a White House Fact Sheet , are stated to be in response to Russia’s “harmful foreign activities,” including efforts to undermine free and fair democratic elections and institutions, malicious cyber activities (including the recent SolarWinds incident), transnational corruption, targeting of dissidents…