On March 31, 2026, the Office of Foreign Assets Control (“OFAC”) issued an advisory (the “Advisory”) regarding sham transactions and their use in evading US sanctions. OFAC described sham transactions as occurring when “blocked persons, often operating through proxies or other intermediaries, effectuate transfers or establish arrangements that conceal–rather than genuinely extinguish–a continuing interest in property.”
On October 22, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced the immediate imposition of full blocking sanctions pursuant to Executive Order (“E.O.”) 14024 against Russian oil companies PJSC Lukoil Oil Company (“Lukoil”) and PJSC Rosneft Oil Company (“Rosneft”), along with over two dozen of their subsidiaries, for operating
In Husch Blackwell’s September 2024 Trade Law Update you’ll learn about the following updates in international trade and supply chain law:
Should you have
In Husch Blackwell’s June 2024 Trade Law Update you’ll learn about the following updates in international trade and supply chain law:
Should you have
In Husch Blackwell’s February 2024 Trade Law Update you’ll learn
about the following updates in international trade and supply chain law:
Should you have
In Husch Blackwell’s January 2024 Trade Law Update you’ll learn
about the following updates in international trade and supply chain law:
Should you have
In Husch Blackwell’s December 2023 Trade Law Update you’ll learn
about the following updates in international trade and supply chain law:
Should you have
Executive Order Imposes New Russia Sanctions for Foreign Financial Institutions and Prohibits Additional Russian Imports
On December 22, 2023, President Biden issued Executive Order 14114, which amended previous Executive Orders in order to authorize the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) to impose additional Russia-related sanctions on foreign financial institutions and
In Husch Blackwell’s November 2023 Trade Law Update you’ll learn
about the following updates in international trade and supply chain law:
Should you have
On June 28, 2022, the Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) and the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a Joint Alert urging financial institutions to be vigilant against efforts by individuals or entities to evade BIS export controls implemented in connection with the Russian Federation’s further invasion of Ukraine. After providing an overview of recent BIS actions in response to Russia’s invasion of Ukraine, the Joint Alert identifies commodities that present “special concern because of their potential diversion to and end use by Russia and Belarus to further their military and defense capabilities,” all of which require a BIS license prior to export or reexport to Russia and Belarus.