On November 15, 2021, the US Treasury Department’s Office of Foreign Assets Control (OFAC) designated the Public Ministry of Nicaragua and nine Nicaraguan government officials as Specially Designated Nationals (SDNs) pursuant to Executive Order (EO) 13851 and the Nicaragua Human
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US Immigration Announces Employment Eligibility Changes for H-4, L-2 and E Spouses
By Liz LaRocca & Dana Delott
Recent changes to US immigration policies and interpretations regarding employment eligibility should reduce uncertainties and delays for dependent spouses in the H-4, L-2, and E visa categories. The changes, which arise from a litigation settlement, are important and address two…
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FDIC and OCC Join President’s Working Group on Financial Markets in Calling for New Stablecoin Legislation, Oversight
On November 1, 2021, the President’s Working Group on Financial Markets (PWG), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) issued a joint report that, among other things, calls on Congress to…
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US Government Targets Eritrea with Sanctions over Ethiopia Crisis
On November 12, 2021, the US Treasury Department’s Office of Foreign Assets Control (OFAC) designated the Eritrean Defense Forces, the Eritrean People’s Front for Democracy and Justice (PFDJ), two government-linked commercial entities, the head of the Eritrean National Security Office,…
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Client Alert: Legislation Would Impact Currency, Commodity, Options, and Digital Asset Markets
On October 28, 2021, the House Rules Committee released the latest version of HR 5376, the Build Back Better Act. This draft reflects the most recent attempt to forge compromise among Democratic lawmakers, as Congress moves towards a vote on…
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Changes Ahead? US Treasury Publishes Outcomes of Sanctions Policy Review
On October 18, 2021, the US Treasury Department published a report of its 2021 Sanctions Review of economic and financial sanctions implemented by the Office of Foreign Assets Control (OFAC) since September 11, 2001. The next day, Deputy Secretary of…
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Cybersecurity Community Beware: US Finally Enacts “Intrusion Software” Rule
They have been almost a decade in the making, but have finally arrived: new U.S. export controls on “cybersecurity items,” including products and technology involving “intrusion software” and IP network communications surveillance. Published today but effective January 19, 2022, the…
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OFAC Issues Compliance Guidance for the Virtual Currency Industry
On October 15, 2021, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued anticipated Sanctions Compliance Guidance for the Virtual Currency Industry and updated two related Frequently Asked Questions (FAQs 559 and 646). OFAC has…
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OFAC Issues Revised Ransomware Advisory
On September 21, 2021, the US Department of the Treasury’s Office of Foreign Asset Control (OFAC) issued an updated advisory on the sanctions risks of facilitating ransomware payments. OFAC issued a prior version of its advisory on October 1, 2020.…
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OFAC’s New Afghanistan-Related Humanitarian Licenses: Opportunities and Challenges
On September 24, 2021, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License 14 (GL-14) and General License 15 (GL-15), authorizing certain types of humanitarian transactions involving Afghanistan that could relate to the Taliban…
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