On November 14, 2025, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) amended two general licenses and issued two new general licenses (“GLs”)authorizing limited transactions involving Open Joint Stock Company Rosneft Oil Company (“Rosneft”) and Public Joint-Stock Company Oil Company Lukoil (“Lukoil”) and entities in which they respectively own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest (collectively “Rosneft and Lukoil Entities”). Rosneft and Lukoil…
On July 1, 2025, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published the International Criminal Court-Related Sanctions Regulations to implement Executive Order (“EO”) 14203, “Imposing Sanctions on the International Criminal Court”, issued on February 6, 2025. EO 14023 authorized sanctions on foreign persons engaged in certain efforts by the International Criminal Court (“ICC”) to target the United States and Israel. EO 14023 In EO 14203, President Trump finds that the ICC…
In less than two weeks, we have seen Syria go from one of the most heavily sanctioned countries on the planet to a country well on the road to establishing normal trade relations with the Western world. The latest flurry of developments started on May 13, 2025, when President Trump caught much of the world by surprise when he said in a speech in Riyadh: “I will be ordering the cessation of sanctions against Syria…
On March 4, 2025, the US Department of State announced the redesignation of Ansarallah (a political movement and militia group in Yemen also known as the Houthis) as a Foreign Terrorist Organization (“FTO”). The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) separately designated seven high-ranking members of Ansarallah as Specially Designated Nationals (“SDNs”) for smuggling weapons into Houthi-controlled areas of Yemen and negotiating weapons procurement from Russia. In addition, OFAC designated…