On July 17, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced certain updates and changes to its Hong Kong-related sanctions program following the expiration of the national emergency declared in Executive Order (“EO”) 13936, The President’s Executive Order on Hong Kong Normalization. Key changes include: What Changed? OFAC explained that the expiration of EO 13936 does not affect the continuing validity of either the HKAA or the Hong Kong…
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…
On May 1, 2026, President Trump signed Executive Order 14404 (“EO 14404”) entitled “Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to United States National Security and Foreign Policy,” which significantly expands the US sanctions framework targeting Cuba. EO 14404 imposed a modern US secondary sanctions regime targeting Cuba that is likely to encourage many non-US companies – particularly those with US assets/business and/or reliance on the US financial system –…
On April 28, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) took a series of Iran-related actions as part of the Administration’s “Economic Fury” campaign of exerting maximum pressure against Iran. Specifically, OFAC (1) issued an alert warning of the sanctions risks of dealing with Chinese “teapot” oil refineries that process Iranian crude oil and (2) published FAQ 1249, which warns that “toll” payments to the Government of Iran (“GoI”)…