Quantum What? U.S. Sanctions Target Russian Quantum Computing
The Director of the U.S. Department of the Treasury’s Office of Foreign Assets Controls (“OFAC”) made two sanctions-related determinations on…
Sanctions Compliance: A Unique Approach for Conglomerates
The U.S. Department of the Treasury’s Office of Foreign Assets Control’s (“OFAC”) January 2022 settlement agreement with Sojitz (Hong Kong)…
Medical Supply and Agricultural Transaction Considerations for Russia/Ukraine: U.S. Sanctions and Export Controls
U.S. economic sanctions programs and export controls generally have a soft spot for transactions related to the supply of agricultural…
Benchmarking Sanctions Compliance Programs with the Help of Prior OFAC Enforcement Actions
When creating or enhancing a U.S. economic sanctions compliance program, businesses will typically refer to certain published guidance from the…
A Little Bit of Guidance on OFAC General License G
Recently, I reviewed a response by the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) to…
OFAC Continues Iran Designations Despite COVID-19 Outbreak
Despite most of the world being in self-quarantine mode to prevent the spread if COVID-19, the United States Department of…
Common Problem, Uncommon Consequence: The State Street Bank and Trust OFAC Enforcement Matter
Last week, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced the issuance of a…
The Evolution of OFAC General Licenses for Legal Services
The United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has discretion to both specifically license particular…
Shock Gen: The Dangers of the OFAC Voluntary Self-Disclosure
Last week, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a settlement with Société…