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Sanctions Targets

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On April 24, 2024, President Biden signed into law a national security package (H.R. 815) that includes the 21st Century Peace through Strength Act, the fourth pillar of a broader foreign aid package to assist Israel, Ukraine, and the Indo-Pacific. The law contains policy provisions under which (i) the statute of limitations for US sanctions violations would be doubled; (ii) frozen Russian state-owned assets could be seized and used to support Ukraine, (iii) additional sanctions…

On April 17, 2024, the US Department of the Treasury’s Office of Foreign Assets Controls (“OFAC”) issued General License 44A (“GL 44A”), authorizing the wind down by 12:01 am EDT on May 31, 2024 of transactions that were previously authorized under GL 44. OFAC also amended a consolidated frequently asked questions (“FAQs”) guidance document (“Updated Guidance”) to reflect the reissued General License 44A. Our previous blog post on the original issuance of GL 44 can…

Last week, the G7 foreign ministers met on the island of Capri in Italy, which is currently serving in the role of the G7 Presidency. As one of the only law firms with offices and sanctions experts in every G7 country, we watched the meeting with great interest to see how the G7 will be approaching sanctions in the near future. We wanted to flag two quick takeaways from the statements coming out of the…

On Saturday, April 20, 2024, after months of negotiations and many twists and turns, the US House of Representatives passed the 21st Century Peace through Strength Act (H.R. 8038). This bill, which is the fourth pillar of a broader foreign aid package to assist Israel, Ukraine, and the Indo-Pacific, contains numerous sanctions and trade-related national security measures. After each of the four foreign security bills were passed on Saturday, they were combined into one package…