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

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

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

OFAC Reaches Settlement with Alfa Laval Subsidiaries Over Iran Referral

On July 19, 2021, the Treasury Department’s Office of Foreign Assets Control (OFAC) announced that it had entered into settlement agreements with two subsidiaries of Alfa Laval AB, the UAE-based Alfa Laval Middle East Ltd. (“AL Middle East”) and the US-based Alfa Laval Inc. (“AL US”) to settle apparent violations of the Iranian Transactions and … Read more

Biden Administration Adds 34 Entities to BIS Entity List

On July 12, 2021, the Commerce Department’s Bureau of Industry and Security (BIS) published a Federal Register notice amending the Export Administration Regulations (EAR) by adding 34 entities to the BIS Entity List under 43 entries. The Entity List prohibits US companies from exporting or transferring US products and technology to listed entities without a … Read more