On July 1, 2026, the Office of Foreign Assets Control (“OFAC”) in the US Treasury Department imposed sanctions on several parties due to links to Brazil-based Primeiro Comando da Capital (i.e., First Capital Command, or “PCC”). This was the first round of sanctions against parties connected to PCC since the US Government’s actions in the spring designating PCC as both a Foreign Terrorist Organization (“FTO”) and a Specially Designated Global Terrorist (“SDGT”). We refer to…
Since issuing its Frequently Asked Questions (“FAQ”) 1249 on April 28, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has updated its position with respect to “toll” payments to Iran for safe passage through the Strait of Hormuz. At the time of its publication, FAQ 1249 made it clear that payments to Iran for “safe passage” through the Strait of Hormuz are prohibited for U.S. persons. However, to further maximize…
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…