On December 13, 2024, the US Treasury Department (âTreasuryâ) issued 35 new questions and answers (âFAQsâ) providing guidance on the November 17, 2024 final rule outlining the US governmentâs Outbound Investment Security Program (âOutbound Investment Rulesâ). Â These Outbound Investment Rules, which become effective January 2, 2025, implement a targeted outbound investment compliance regime called for by Executive Order (EO) 14105 issued by President Biden on August 9, 2023. The full list of published FAQs can…
On November 21, 2024, the US Department of the Treasuryâs Office of Foreign Assets Control (âOFACâ) designated dozens of Russian banks, including Gazprombank and other Russian banks, securities registrars, and finance officials, to the List of Specially Designated Nationals and Blocked Persons (âSDN Listâ). The full SDN designation of Gazprombank, the largest remaining Russian bank, is particularly notable given its role in supporting gas flows between Russia and remaining European and other customers. On the…
In October 2024, the United States Department of the Treasuryâs Office of Foreign Assets Control (âOFACâ) and the United Kingdomâs Office of Financial Sanctions Implementation (âOFSIâ) celebrated the second anniversary of their Enhanced Partnership. This collaboration, initiated in response to the increasingly complex geopolitical landscape, aims to bolster the effectiveness of sanctions as a global tool for national security. Over the past two years, OFAC and OFSI have worked closely to coordinate their sanctions regimes,…
On October 30, 2024, the US Government imposed sanctions on hundreds of entities and individuals across the globe, primarily in response to Russiaâs continued war in Ukraine, and amended US export controls related to Russia and Belarus. Below, we describe the key actions taken by the US Departments of the Treasury, State, and Commerce. 1. OFAC Actions With the aim of disrupting global sanctions evasion networks and domestic suppliers to Russiaâs military-industrial base, the US…