On July 27, 2026, the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a statement (here) of enforcement policy committing not to take supervisory or enforcement action against US financial institutions under the Bank Secrecy Act (“BSA”) in connection with the provision of authorized financial services provided in Venezuela. The statement was issued in consultation with the Internal Revenue Service and the staffs of the Board of Governors of the Federal Reserve…
On July 10, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License No. 2 (“GL 2”) under the Democratic Republic of the Congo Sanctions Regulations (the “DRCSR”) as the eastern Democratic Republic of the Congo (“DRC”) continues to face significant humanitarian challenges, including an Ebola outbreak in the region. GL 2 goes beyond the existing general license found in section 547.513 of the DRCSR, which is limited to…
On July 10, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a series of Iran-related sanctions designations targeting Iranian financial facilitator Ali Ansari and his financial network, as well as several Iranian exchange houses accused of facilitating transactions for sanctioned Iranian banks. Concurrently, OFAC issued General License Y (“GL Y”), authorizing the temporary wind down of transactions involving Smart Global Limited, a newly designated holding company allegedly controlled by Ansari.…
On July 7, 2026, the US Treasury Department’s Office of Foreign Assets Control revoked Iran General License X (“GL X”), which would have otherwise been valid through August 21, 2026. GL X was issued in June to authorize the production, delivery, and sale of Iranian crude, petrochemical products, and petroleum products. See our earlier summary here. OFAC replaced GL X with a narrow wind-down authorization issued as Iran General License X1 (“GL X1”). Under GL…