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Recently, the U.S. Treasury Department s Office of Foreign
Assets Control ( OFAC ) sanctioned various individuals
and entities connected to Russia s technology sector and also
expanded sanctions against dealings in Russian sovereign
debt. In addition to these immediate actions, President Biden
also issued a new Executive Order which will significantly expand
OFAC s authority to impose future sanctions against Russia.
Background
The White House published a Fact Sheet which explains the recent sanctions
actions were a response to Russian election interference and
cyber-attacks directed at the United States. A month prior to
Last week, leaders of the Association for Southeast Asian Nations (ASEAN) held an emergency summit on Myanmar. They charted a way forward while Gen. Min Aung Hlaing sat alongside their negotiating table. Hlaing is the same man who oversaw genocide against the Rohingya, attempted a coup to preserve his privileges as commander-in-chief, and is now presiding over a campaign to terrorize his own people into submission.
The fate of Myanmar, though, will not be determined around a table where the people of Myanmar are not represented. Myanmar’s protestors remain resolute in rejecting the military’s attempted coup. Meanwhile, the military has stated that it will only recognize ASEAN’s mediation role once the “situation returns to stability.” As ASEAN clarifies its role, the United States should build a partnership with key member-states, underscoring the risk a collapsing Myanmar presents to ASEAN’s legitimacy, but also the region’s opportunity to respond in ways that en
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On April 29, 2021, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced two settlements of potential civil liability with two companies over their apparent violations of its regulations. The companies, MoneyGram Payment Systems, Inc. (MoneyGram) and SAP SE (SAP), operate in sectors of the economy payments and software that present unique sanctions risks and compliance challenges.
The two settlements highlight many of those risks, such as the reliance on third-party resellers, the integration of newly acquired companies, and contracting with the US government. They are part of a trend of increased OFAC enforcement
Polotsk Steklovolokno OAO
Wind down transactions in excess of $50,000 must be reported to the U.S. Department of State no later than 30 days after executing the transaction.
Under the previous General License 2G and its predecessors, most business with these companies was authorized by OFAC. Given this change, and the prominence of these state-owned entities in Belarus’s economy, U.S. companies that do business in Belarus should carefully review their business relationships to ensure that any dealings involving these nine entities and their subsidiaries are wound down prior to June 3, 2021.
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The Biden administration continues to utilize United States trade sanctions and export controls as a key tool in its efforts to put pressure on China, Myanmar/Burma and Russia. Since our last update, actions by the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC), the U.S. Commerce Department’s Bureau of Industry and Security (BIS), the U.S. State Department (State) and the U.S. State Department’s Directorate of Defense Trade Controls (DDTC) have been bolstered by similar actions taken by U.S. allies, indicating multilateral support for the Biden administration’s efforts to combat ongoing human rights crises and national security concerns in these regions.