Ghost Fleet Update – US probes 30 ship managers for information regarding 100 vessels suspected of Russia oil sanctions violations.

On November 10, 2023, the Office of Foreign Assets Control (“OFAC”) sent notices to ship management companies in nearly 30 countries inquiring about the operations of 100 vessels suspected of facilitating operations in violations of U.S. sanctions related to Russian oil. While OFAC refused to “confirm or comment on investigations or enforcement actions” an OFAC … Read more

OFAC Imposes Sanctions Restrictions on Myanmar’s State-Owned Oil and Gas Company

On October 31, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) imposed additional sanctions related to Myanmar. In particular, OFAC issued Directive 1 pursuant to Executive Order (“E.O.”) 14014, which imposes extensive sanctions restrictions on Myanma Oil and Gas Enterprise (“MOGE”). In addition, OFAC designated additional individuals and entities in … Read more

With Wide-Ranging New Sanctions, United States Treasury Department Targets Russian Technology Supply Chains, Military-Linked Elites and Industrial Base, and More

On Thursday, September 14, the U.S. Department of the Treasury’s Office of Foreign Assets (“OFAC”) imposed nearly 100 sanctions on Russian elites and Russia’s industrial base, financial institutions, and technology suppliers. The United States Secretary of the Treasury, Janet Yellen, stated that: “[T]he United States is continuing our relentless work to target Russia’s military supply … Read more

BIDEN ADMINISTRATION ANNOUNCES NEW US-CHINA OUTBOUND INVESTMENT SANCTIONS

On August 9, 2023, President Biden issued an Executive Order (the “Executive Order”) restricting certain U.S.  investments in Chinese companies which produce technologies and products raising US national security concerns.” On the same day, the Treasury Department issued an “Advanced Notice of Proposed Rulemaking” (“ANPR”) commencing the process to issue regulations imposing the new investment … Read more

United States Departments of Treasury, Commerce, and Justice Issue “Tri-Seal” Compliance Note on Voluntary Self-Disclosure of Potential Violations

On Wednesday, July 26, 2023, the United States Department of Justice, Department of Commerce’s Bureau of Industry and Security (“BIS”), and Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a tri-seal compliance note (the “Note”) focusing on the voluntary self-disclosure policies that apply to U.S. sanctions, export controls, and other national security … Read more

OFAC Sanctions Multiple Entities to Impede Russian Access to Battlefield Supplies and Target Revenue Generators

On July 20, 2023, the United States Department of the Treasury’s Office of Foreign Assets control (“OFAC”) sanctioned multiple entities and issued general licenses to further implement the commitments made by the G7 Leaders in February and May 2023 by inhibiting Russia’s access to products that support its military and war efforts, reducing Russia’s revenue … Read more

Publication of a Joint Fact Sheet on Understanding UK and U.S. Russia-Related Sanctions and the Provision of Humanitarian Assistance

On June 28, 2023, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) and His Majesty’s Treasury’s Office of Financial Sanctions Implementation (“OFSI”) published a joint Humanitarian Assistance and Food Security Fact Sheet (“Joint Fact Sheet”) that provides clarity on U.S. and UK Russia-related sanctions and the relevant authorizations, exceptions, and … Read more

OFAC Announces Sanctions on Illicit Gold Companies Funding Wagner Forces and Wagner Group Facilitator, New Burma Sanctions

On June 27, 2023, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) imposed sanctions on various entities and one individual connected to the Russian mercenary group PMC Wagner (“Wagner Group”) and its founder and owner Yevgeniy Prigozhin (“Prigozhin”). In this announcement, which can be read in full here, OFAC sanctioned … Read more

OFAC Enters Settlement Agreement With Swedbank Latvia for $3,430,900 Related to Apparent Violations of Crimea Sanctions

On June 20, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) entered a settlement agreement with Swedbank AS (Latvia) (“Swedbank Latvia”), a subsidiary of Swedbank AB, headquartered in Stockholm, Sweden. According to a press release, Swedbank Latvia agreed to pay $3,430,900 to settle its potential civil liability for 386 apparent … Read more