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 December 2, 2021, the EU, UK, US, and Canada all imposed additional coordinated sanctions on Belarus as a punitive action against the government led by President Alexander Lukashenko, which has been accused of human rights violations and creating a migrant crisis at Belarusian borders. As further described below, the sanctions included the designation of a number of parties (individuals and entities), whilst certain individuals will also be subject to travel bans preventing them entering…
On October 15, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) published sanctions compliance guidance for the virtual currency industry (the “Guidance”), given that “the growing prevalence of virtual currency … brings greater exposure to sanctions risk.” This Guidance follows (1) the recent and first-ever designation of a virtual currency exchange (SUEX OTC, S.R.O) by the OFAC (see our recent post on this here), and (2) the launch of the National Cryptocurrency Enforcement…
On September 24, 2021, the US Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued two General Licenses—(i) General License 14, “Authorizing Humanitarian Activities in Afghanistan” (“GL 14”), and (ii) General License 15, “Transactions Related to the Exportation or Reexportation of Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates in Afghanistan” (“GL 15”)—to “support the continued flow of humanitarian assistance to the people of Afghanistan and other activities that support…