Ukraine/Russia Sanctions: OFAC Authorizes Derivatives Linked to Prohibited Debt and Equity Under OFAC Directives 1, 2 or 3

Ukraine/Russia Sanctions: OFAC General License No. 1B Authorizes Derivative Transactions Linked to Prohibited Debt Under OFAC Directives 1, 2 or 3 On November 28, 2017, the Treasury Department’s Office of Foreign Assets Control (OFAC) issued General License No. 1B under Executive Order 13,662.[i] General License 1B authorizes “[a]ll transactions by U.S. persons, wherever located, and…

Read More

Do State Regulators Like the NYDFS Have Authority to Enforce OFAC Sanctions?

Robust Enforcement of OFAC Sanctions by Federal Authorities In recent years the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and other federal authorities have robustly enforced OFAC-administered sanctions against banks, particularly U.S. branches of foreign banks. Notable for their number, successiveness, and monetary penalty amounts imposed—often for U.S. sanctions and related…

Read More

U.S. Sectoral Sanctions Targeting Russian Financial Services: OFAC Directive 1

United States Adds Russian Direct Investment Fund, Other Russian Financial Services Actors to Sectoral Sanctions List Certain Financing, Debt, and Equity Transactions Remain Prohibited; Action Relevant to U.S. Persons and Non-U.S. Persons (particularly Middle East- and Asia-based) Sanctioned Status Made Explicit On July 30, 2015, the U.S. Department of the Treasury’s Office of Foreign Assets…

Read More