OFAC expands sectoral sanctions on Belarus

On December 2, 2021, the Office of Foreign Assets Control (OFAC) of the US Department of the Treasury took several actions to increase sanctions pressure on Belarusian government, including the introduction of a new sectoral sanctions regime (Directive 1) targeting certain Belarusian sovereign debt, the designation of 35 additional persons and entities to the Specially … Read more


On 2 December 2021 the Australian Parliament passed the Autonomous Sanctions Amendment (Magnitsky-style and Other Thematic Sanctions) Bill 2021 (Bill) introducing a new thematic sanctions regime to the Autonomous Sanctions Act 2011 (Act) and Autonomous Sanctions Regulations 2011 (Regulations). As outlined in our previous update, the amendments expand Australia’s existing autonomous sanctions regime (which enabled Australia to … Read more

OFAC Extends Venezuela General License 8

On November 24, OFAC issued General License 8I, Authorizing Transactions Involving Petróleos de Venezuela, S.A. (“PdVSA”) Necessary for the Limited Maintenance of Essential Operations in Venezuela or the Wind Down of Operations in Venezuela for Certain Entities (“GL 8I.”). GL 8I is available here. GL 8I replaces and supersedes General License No. 8H (“GL 8H”), … Read more


This analysis was first published on Lexis®PSL on 29 October 2021 and can be found here (subscription required). Ivan Teselkin, partner, Maria Dolotova, of counsel, Alexander Gridasov, senior associate, and Sergei Eremin, senior associate, of Herbert Smith Freehills provide an overview of Russian court decisions on the impact of recent amendments to Russian law relating to international … Read more

Bureau of Industry & Security Issues New Export Controls on “Cybersecurity Items”

On October 21, 2021, the Bureau of Industry & Security (BIS) of the US Department of Commerce issued a significant interim final rule (the Interim Rule).  The Interim Rule, reflecting an overall recent government emphasis on cybersecurity and ransomware issues, establishes new export controls for “cybersecurity items” such as intrusion software and network surveillance equipment … Read more

OFAC and FinCEN Publish Virtual Currency Industry and Ransomware Guidance

On October 15, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued an industry-specific brochure entitled, “Sanctions Compliance Guidance for the Virtual Currency Industry” (the “OFAC Guidance”). According to a press release, the OFAC Guidance “outlines sanctions compliance best practices tailored to the unique risks posed in this dynamic space, … Read more

Designated: A Sanctions Podcast EP3: Cross over event with The Bettor’s Verdict

In a special podcast cross over event, the Designated team joins The Bettor’s Verdict to discuss the Impact of Crypto on Sanctions and AML Laws in the United States.  In this episode, Designated host Jonathan Cross, is joined by The Bettor’s Verdict host Steve Jacobs, and Herbert Smith Freehills Partner John O’Donnell. Jonathan, Steven and … Read more

The U.S. Establishes a New Ethiopia Sanctions Regime

On September 17, 2021, the President signed Executive Order (“E.O.”) 14046, imposing sanctions on certain persons with respect to the humanitarian and human rights crisis in Ethiopia. According to a Fact Sheet issued by the White House, the conflict in Ethiopia “has sparked one of the worst humanitarian and human rights crises in the world, … Read more

OFAC Enters Settlement Agreement With a U.S. Company Related to Certain Exports to Iran Through Non-U.S. Distributors

On September 9, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) entered a settlement agreement with NewTek, Inc. (“NewTek”), headquartered in San Antonio, Texas. According to a press release, NewTek agreed to pay $189,483 to settle its potential civil liability for 52 apparent violations of the Iranian Transactions and Sanctions … Read more