On July 23, 2026, the US Department of State designated multiple entities and individuals in Cuba, and the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued three new Cuba-related general licenses. The actions are intended to further restrict revenue streams supporting the Cuban government, including activities tied to the energy sector, sanctions evasion networks, financial services, and Cuba’s overseas medical missions program. The designations and general licenses were issued under Executive…
On July 27, 2026, the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a statement (here) of enforcement policy committing not to take supervisory or enforcement action against US financial institutions under the Bank Secrecy Act (“BSA”) in connection with the provision of authorized financial services provided in Venezuela. The statement was issued in consultation with the Internal Revenue Service and the staffs of the Board of Governors of the Federal Reserve…
On July 10, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License No. 2 (“GL 2”) under the Democratic Republic of the Congo Sanctions Regulations (the “DRCSR”) as the eastern Democratic Republic of the Congo (“DRC”) continues to face significant humanitarian challenges, including an Ebola outbreak in the region. GL 2 goes beyond the existing general license found in section 547.513 of the DRCSR, which is limited to…
On July 8, 2026, the US Department of State announced that President Trump had notified Congress of his administration’s intent to rescind Syria’s designation as a State Sponsor of Terrorism (“SST”). The notification initiates a 45-day period that must elapse before the rescission takes effect. In the accompanying press statement, Secretary of State Marco Rubio said that “[l]ifting sanctions on Syria will unlock international trade and investment, give Syria a chance to rebuild, and open…