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Eunkyung Kim Shin

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On June 14, 2023, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) published a Fact Sheet providing a helpful consolidated summary of the various existing exemptions, exceptions, and authorizations relating to the provision of humanitarian assistance that are available under certain US sanctions programs to respond to the COVID-19 pandemic. The Fact Sheet is informational only and does not supersede any legal obligations or create new, or modify existing, exemptions, exceptions, or authorizations. Fact…

On May 4, 2023, the President Biden issued Executive Order 14098 (“EO 14098”) establishing a sanctions authority that authorizes the US Government to imposes sanctions on persons or entities in Sudan in connection with “the military’s seizure of power in October 2021 and the outbreak of inter-service fighting in April 2023.” While no sanctions have been imposed under EO 14098 to date, this new Sudan sanctions authority authorizes the US Government to issue asset blocking…

On February 3, 2023, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published a determination pursuant to sections 1(a)(ii), 1(b), and 5 of Executive Order 14071 and a determination pursuant to section 1(a)(ii) of Executive Order 14071 (“Determinations”) to implement the price cap policy for Russian petroleum products, building on earlier determinations related to Russian crude oil.  OFAC also issued an updated guidance document relating to the price cap policy for Russian crude oil and petroleum…

The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), the US Department of State (“State”), the US Department of Commerce (“Commerce”), and the US Department of Energy (“DOE”) issued rules adjusting maximum civil monetary penalties (“CMPs”) under the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015, as outlined below. (For additional years of CMPs, see our previous blog post available here.) OFAC CMP Adjustments Under OFAC’s final rule issued on January 13,…