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OFAC

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The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) recently designated as Specially Designated Nationals (“SDNs”) a number of entities linked to the Iranian steel, aluminum, and iron sectors that are likely to be of particular interest for companies doing trade in or with the Middle East or financial institutions financing trade and business in the region. This post highlights OFAC’s recent action and outlines some practical considerations. On 25 June 2020,…

On June 5, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) published four Frequently Asked Questions (the “FAQs”) regarding Iran-related sanctions under Executive Order 13902 (“EO 13902”). EO 13902 authorizes the imposition of secondary sanctions targeting the Iranian construction, mining, manufacturing, and textile sectors and persons engaged in “significant transactions” or providing “material support” to parties designated pursuant to the order. Our blog post regarding EO 13902 is available here. The FAQs…

On June 3, 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued new Syria-Related Sanctions Regulations (the “Regulations”), effective June 5, 2020, to implement Executive Order 13894 (“EO 13894”) issued by the President on October 14, 2019 in light of Turkey’s military actions in Syria. The Regulations are a codification of EO 13894 and do not represent new sanctions against Syria. They are also separate from US comprehensive sanctions targeting Syria under…

On May 14, 2020, the US Department of State, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), and the US Coast Guard issued guidance to the private sector aimed at preventing deceptive shipping practices used in sanctions evasion, smuggling, facilitation of terrorism, and other criminal activity (the “Advisory”).  The Advisory focuses on tactics recently used by malign actors to evade sanctions and sets out a non-exhaustive list of best practices companies…