On June 30, President Trump signed Executive Order 14312, “Providing for the Revocation of Syria Sanctions” (EO), which formally terminates many U.S. sanctions on Syria. Public reports indicate that the European Union has also lifted nearly all sanctions on Syria.Continue Reading U.S. Government Ends Sanctions on Syria
Sanctions (OFAC)
Sanctions Enforcement Update: DOJ Declines Prosecution After Post-Acquisition Disclosure
In June 2025, the U.S. Treasury’s Office of Foreign Assets Control (OFAC) announced that Unicat Catalyst Technologies, LLC (Unicat), a Texas-based petrochemical company, had agreed to settle its potential civil liability relating to U.S. sanctions on Iran and Venezuela. OFAC is the primary U.S. government agency that administers and enforces U.S. sanctions.Continue Reading Sanctions Enforcement Update: DOJ Declines Prosecution After Post-Acquisition Disclosure
U.S. Government Eases Some Restrictions on Syria
On May 23, 2025, the U.S. Treasury Department, Office of Foreign Assets Control (OFAC) announced several actions to provide sanctions relief to Syria. OFAC is the primary government agency responsible for administering U.S. economic sanctions.Continue Reading U.S. Government Eases Some Restrictions on Syria
America First Investment Policy Sets Sights on China
On February 21, the Trump Administration released the America First Investment Policy (the memo or memorandum). The wide-ranging memo formally targets investment from the People’s Republic of China, including Hong Kong and Macau (collectively, the PRC), in sensitive U.S. sectors, modifies aspects of the Committee for Foreign Investment in the United States (CFIUS) process, and proposes new restrictions on outbound investment. Continue Reading America First Investment Policy Sets Sights on China
Haas Automation Agrees to Pay More Than $2.5 Million to Settle Sanctions and EAR Violations
On January 17, the Treasury Department’s Office of Foreign Assets Control (OFAC) and the Commerce Department’s Bureau of Industry and Security (BIS) announced that Haas Automation Inc. (Haas) agreed to settle potential civil liability related to multiple violations of the Ukraine-/Russia-related Sanctions Regulations and the Export Administration Regulations (EAR). Continue Reading Haas Automation Agrees to Pay More Than $2.5 Million to Settle Sanctions and EAR Violations
German Company Pays $14.55 Million to Settle Violations of U.S. Sanctions on Iran
Key Points:
- Long-arm of U.S. sanctions jurisdiction reaches conduct by European company.
- Violation involved shipment to Iran from Australia, a close U.S. ally.
On December 3, the Treasury Department’s Office of Foreign Assets Control (OFAC) announced that Aiotec GmbH, a German supplier of industrial equipment for the energy sector, agreed to pay $14,550,000 to settle its potential civil liability for violating the Iranian Transactions and Sanctions Regulations (ITSR). The settlement agreement can be found here. The press release can be found here.Continue Reading German Company Pays $14.55 Million to Settle Violations of U.S. Sanctions on Iran
Swiss Finance Company to Pay Almost $4 Million for Sanctions Violations
On March 14, the U.S. Treasury Department, Office of Foreign Assets Control (OFAC) announced that EFG International AG (EFG), a Switzerland-based bank, had agreed to pay roughly $3.74 million to settle allegations that it had violated multiple U.S. sanctions regimes. Continue Reading Swiss Finance Company to Pay Almost $4 Million for Sanctions Violations
Insights on Russian Sanctions in The Washington Post
I recently shared insights on the landscape of U.S. sanctions on Russia for a story in The Washington Post entitled “Why the U.S. Put a $1 Million Bounty on a Russian Yacht’s Alleged Manager.”Continue Reading Insights on Russian Sanctions in The Washington Post
Examining the 3M Sanctions Settlement
In an article for Law360, I examined the recent settlement between the U.S. Department of the Treasury’s Office of Foreign Assets Control and the 3M Company for nearly $10 million to resolve apparent violations of U.S. sanctions on Iran. Continue Reading Examining the 3M Sanctions Settlement
Tri-Seal Compliance Note on Voluntary Self-Disclosure Released by Departments of Commerce, Justice, and Treasury
On July 26, the Department of Commerce, Department of the Treasury, and Department of Justice released a Tri-Seal Compliance Note (July Note) providing guidance on voluntary self-disclosure of potential violations of U.S. sanctions, export controls, and other national security laws. Continue Reading Tri-Seal Compliance Note on Voluntary Self-Disclosure Released by Departments of Commerce, Justice, and Treasury