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US Imposed Sanctions

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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…

Our clients across every industry are asking us what we expect to happen with the Russia sanctions under the Trump Administration.  Will President Trump relax the Russia sanctions, and if so, when?  All or only some of them?  Or will President Trump ramp up the Russia sanctions to put pressure on Russia to agree to a peace deal with Ukraine?  Will Congress get involved, and how?  We will be tackling these questions and more in…

On February 20, 2025, the US Department of State designated several international cartels and transnational criminal organizations as Foreign Terrorist Organizations (“FTOs”) pursuant to section 219 of the Immigration and Nationality Act and as Specially Designated Global Terrorists (“SDGTs”) pursuant to Executive Order (“EO”) 13224. These parties have been designated for “threaten[ing] the safety of the American people, the security of the United States, and the stability of the international order in the Western Hemisphere,”…

On 11 February 2025, we saw the first public multi-jurisdictional coordinated sanctions action under the Trump Administration when the United States, Australia, and the UK announced joint sanctions against alleged key members of a Russian cybercrime supply chain. This action was taken by the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), Australia’s Department of Foreign Affairs and Trade, and the UK Foreign Commonwealth and Development Office (“UK FCDO”).  See the US…