OFAC Sanctions Cryptocurrency Exchange to Combat Ransomware Payments, Releases New Ransomware Guidance

    On September 21, 2021, the Office of Foreign Assets Control (“OFAC”) of the Treasury Department issued an Updated Advisory on Potential Sanctions Risks for Facilitating Ransomware Payments (“Updated Advisory”), which warns of the sanctions risks of making or facilitating ransomware payments and provides expanded guidance on steps that companies may take to mitigate ransomware risk. … Read more

    Companies May Risk Violating U.S. Sanctions Against the Taliban by Conducting Business With the Government of Afghanistan

    Now that the Taliban controls Afghanistan, many businesses with economic interests or investments in the country are reevaluating potential sanctions risks. Indeed, a former OFAC official explained that, “[t]his is a new world,” and that he could not “think of any case in which a terrorist group that’s already designated became the power in charge … Read more

    European Commission launches new public consultation seeking feedback to possible amendments to the EU Blocking Statute

    In August 2021, we published a post about the European Commission’s roadmap / inception impact assessment in relation to its review of the current Blocking Statute (Regulation 2271/96). On 31 August 2021, the European Commission closed the initial feedback period for this impact assessment and, as a next step, has now launched a public consultation process seeking further feedback … Read more

    Designated: A Sanctions Podcast EP2: History of US Sanctions Under the JCPOA May Offer Insight to Terms of Renewed JCPOA Participation

    In this episode, Jonathan Cross, Brittany Crosby-Banyai and Dan Hudson discuss the history of the Iran sanctions program under the Iranian nuclear deal, known as the Joint Comprehensive Plan of Action (“JCPOA”). They also analyze the mechanisms by which sanctions were re-imposed when the US left the agreement. These considerations offer insight as to the … Read more

    OFAC Enters Settlement Agreement With a Non-U.S. Company, and its U.S. Parent Company, Related to Violations of Iran and Syria Sanctions

    On August 27, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) entered a settlement agreement with First Bank SA (“First Bank”), located in Romania, and its U.S. parent company, JC Flowers & Co. (“JC Flowers”). According to a press release, the companies agreed to pay $862,318 to settle potential civil … Read more

    Proposed reforms to Australia’s sanctions regime to target corruption, cyber-crime, human rights violations

    The Australian Government has announced plans to implement a targeted, Magnitsky-style sanctions regime by the end of 2021. What are the implications of the proposed reforms? The proposed reforms would expand Australia’s current country-based autonomous sanctions framework to include targeted sanctions focused on themes of conduct. This includes proliferation of malicious cyber activity, gross human … Read more

    UK, US and Canada impose additional sanctions on Belarus

    On 9 August 2021, the UK, US and Canadian governments announced the imposition of additional sanctions on Belarus. These new measures follow the coordinated imposition of sanctions against Belarus by the EU, UK, Canada and the US in June 2021. The new US measures involve, among other restrictions: new US secondary sanctions applicable to companies … Read more

    OFAC settlement with online payment-services company highlights key OFAC expectations in sanctions compliance programs

    On July 23, 2021, the Office of Foreign Assets Control (OFAC) of the US Department of the Treasury entered a settlement agreement with an online payment-services company business based in New York, Payoneer Inc. (Payoneer). Payoneer, which went public on the Nasdaq exchange in June 2021, provides digital payment services and online money transfer services … Read more