Sanctions

Sanctions published last week by OFAC effectively weaponize access to cloud platforms, identity systems, and communication tools, highlighting the vulnerability of global institutions reliant on U.S.-based digital infrastructure.

Treasury’s Office of Foreign Assets Control (OFAC) has imposed sanctions on a global network of entities and individuals facilitating billions of dollars in illicit Iranian oil sales, including smuggling operations benefiting Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF), a designated Foreign Terrorist Organization.

Treasury’s Office of Foreign Assets Control (OFAC) has sanctioned seven senior officials and one entity linked to Al-Qard Al-Hassan (AQAH), a Hizballah-controlled financial institution …

Treasury’s Office of Foreign Assets Control (OFAC) announced a $608,825 settlement with Key Holding, LLC to resolve its potential civil liability for 36 apparent violations of the Cuban Assets Control Regulations (CACR), 31 C.F.R. part 515. The violations stemmed from the conduct of a Colombian subsidiary that managed logistics for freight shipments to Cuba between January 2022 and July 2023.

President Trump has revoked key U.S. sanctions on Syria, citing changed circumstances and the emergence of a transitional Syrian government.

Treasury’s Office of Foreign Assets Control (OFAC) has designated Aeza Group, a Russia-based bulletproof hosting (BPH) provider, for enabling a range of cybercriminal activities, including ransomware operations, credential theft, and darknet drug trafficking.

President Trump has signed a National Security Presidential Memorandum (NSPM) reissuing and amending NSPM-5, originally issued in 2017, to restore and strengthen U.S. policy toward Cuba. The June 30 directive rolls back policies from the Biden administration and reimposes a broad set of restrictions on travel, trade, and diplomatic engagement, with the stated aim of promoting human rights, economic freedom, and democratic governance in Cuba.

On June 30, the President issued an  Executive Order "Providing for the Revocation of Syria Sanctions" that removes U.S. sanctions on Syria, effective July 1, 2025. To implement the President's …

The Treasury’s Office of Foreign Assets Control (OFAC) has issued a notice requesting public comment on a proposed electronic Sanctions Reconsideration Portal. The initiative seeks to streamline administrative reconsideration requests submitted under OFAC’s Reporting, Procedures and Penalties Regulations (31 CFR § 501.807) by sanctioned individuals or entities.

The Solicitors Regulation Authority (SRA) has issued a formal rebuke to Steptoe International (UK) LLP, the London office of Washington, D.C.-headquartered Steptoe & Johnson LLP, for breaching the UK’s Russia sanctions regime. The breaches involved work for two unnamed clients and arose from what the firm described as inadvertent human error by a single fee-earner.

A bipartisan coalition of U.S. lawmakers has introduced the Burma Genocide Accountability and Protection Act (“Burma GAP Act”) to spur U.S. leadership in confronting ongoing atrocities committed by the Burmese military against the Rohingya people.  The initiative comes as the Trump Administration calls for an end to the prosecution of military atrocities in Burma, Syria and by Russian forces in Ukraine.

The U.S. Treasury Department is urging the D.C. Circuit Court of Appeals to dismiss Rheingold Edelmetall AG’s challenge to its designation on the Specially Designated Nationals (SDN) list. In …

Treasury’s Office of Foreign Assets Control (OFAC) Friday sanctioned one individual, eight entities, and identified a vessel as blocked property for their roles in facilitating sensitive equipment shipments to Iran’s defense industry, including entities affiliated with the Islamic Revolutionary Guard Corps (IRGC). The Treasury also imposed further sanctions on the Islamic Republic's Yemeni allies, Ansarallah, known as the Houthis.

The U.S. Treasury and State Departments announced a series of coordinated sanctions and regulatory actions to pressure the Iranian regime. Recent measures target Iran’s shadow banking operations, oil smuggling network, and military procurement activities.

The U.S. Department of the Treasury issued new sanctions last week targeting five “sham” charities and associated individuals across Europe, North Africa and the Middle East for alleged support to Palestinian terrorist organizations, a move one former official said should remind donors to stay vigilant.

The transatlantic sanctions alliance among the United States (U.S.), the United Kingdom (UK), and the European Union (EU) has demonstrated significant cohesion, particularly in response to Russia's invasion of Ukraine. However, critical divergences in implementation, scope, and enforcement complicate compliance for multinational entities. As sanctions regimes evolve—often with extraterritorial implications—legal and compliance professionals must anticipate conflicts and establish adaptive, harmonized internal frameworks. This article analyzes these key differences and offers practical guidance for aligning compliance programs across jurisdictions.

Dentons published a client alert which concludes that Ukrainian sanctions can apply extraterritorially.

Treasury’s Office of Foreign Assets Control (OFAC) has designated over 30 individuals and entities linked to Iran’s sprawling “shadow banking” infrastructure, including three Iranian brothers accused of laundering billions of dollars through international financial systems to support Iran’s oil exports, weapons procurement, and terrorist proxies.

On June 6, 2025, the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an advisory detailing Iran’s illicit financial activities, including oil smuggling, shadow banking, and weapons procurement. This advisory supersedes the 2018 version, providing updated insights and red flags for financial institutions.

The White House is pressing Sen. Lindsey Graham (R-SC) to significantly revise the Sanctioning Russia Act of 2025 , which currently commands broad bipartisan support in the Senate. Congressional aides warned that such changes would “render Graham’s bill toothless.”

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