OFAC

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The Department of Treasury’s Office of Foreign Asset Controls (“OFAC”) administers financial and economic sanctions against specific countries in response to some form of wrongdoing. OFAC sanctions are targeted broadly against 1) foreign governments and political entities, 2) individuals and groups ranging from terrorists and drug cartels to banks and other financial institutes that support those types of activities, 3) entities such as charities linked to terrorism, and 4) certain activities such as those that would lead to nuclear proliferation or otherwise violation U.S. policy interests.

Well-known sanctions programs include complete embargoes or more limited restrictions on trade with Cuba, Iran, Syria, and North Korea. Other programs include more targeted sanctions on the property of specified people from countries including Russia, Venezuela, Belarus, the Congo, and elsewhere. Collectively, such individuals and companies are called "Specially Designated Nationals" or "SDNs." Their assets are blocked, and U.S. persons are prohibited from dealing with them. Both the sanctions programs and the SDN List are constantly changing and companies that do business internationally, particularly in political ‘hot spots’ are well advised to constantly monitor OFAC developments.

OFAC’s sanctions apply to all U.S. citizens and permanent residents wherever they are located. It also applies to any person who is physically in the United States regardless of his citizenship. U.S. companies and all branches of U.S. organizations throughout the world remain subject to OFAC. Likewise, U.S. branches or offices (physically located in the U.S.) of foreign corporations are subject to OFAC.

Attorneys at Barnes, Richardson are well versed in sanction law and can provide guidance on how to tailor transactions, including financial transactions, so they remain complaint with the OFAC law. Barnes, Richardson attorneys assist companies in all areas of OFAC compliance, including building and auditing robust OFAC compliance programs, preparing and submitting voluntary disclosures to OFAC, and engaging in other representations before that agency.

Apr. 29, 2025: Administration to Ease Auto and Parts Tariffs
Apr. 29, 2025: Latest Executive Order Limits Tariff Stacking
Apr. 24, 2025: De Minimis Ending for Goods of China (and Hong Kong)
Apr. 23, 2025: Section 232 Takes on Medium and Heavy-Duty Trucks
Apr. 17, 2025: Another Rapid Response Mechanism Request on the Books
Apr. 16, 2025: Trump Orders National Security Investigation for Critical Minerals
Apr. 10, 2025: EU to Pause Countermeasure Response for 90 Days
Apr. 9, 2025: EU and China Strike Back with Tariffs on U.S. Imports
Apr. 9, 2025: Trump Announces 90-Day Pause on Country-Specific Reciprocal Tariffs
Apr. 8, 2025: Customs Issues "Reciprocal Tariffs" Guidance
Apr. 8, 2025: White House Indicates China Will Face (at least) 104% Duties
Apr. 4, 2025: Tariff Subheading Guidance for ‘Reciprocal Tariffs' Published
Apr. 4, 2025: Global Response to U.S. ‘Reciprocal Tariffs'
Apr. 3, 2025: Correction and Exclusions for ‘Reciprocal Tariffs' Published
Apr. 2, 2025: Trump Announces 25% Tariff on Passenger Vehicles, Light Trucks, and Auto Parts
Apr. 2, 2025: Changes to De Minimis Duty Free Treatment for Good from China and Hong Kong
Apr. 2, 2025: Reciprocal Tariffs Announced
Mar. 27, 2025: President Trump Announces 25% on Autos and Light Trucks
Mar. 25, 2025: 25% Tariffs on Countries that Import Venezuela Oil
Mar. 19, 2025: AD/CVD Petitions Filed for Corrugated Boxes from China and Vietnam
Mar. 13, 2025: Countries Around the World Strike Back at the Trump Administrations Increase in Tariffs
Mar. 11, 2025: U.S. Seeking Broad Trade Agreement with India
Mar. 11, 2025: As Tariffs Loom, Steel and Aluminum Rules Remain in Flux with Lost Exclusions and Increased Duties
Mar. 11, 2025: CBP Guidance on Duties on Imports of Steel and Steel Derivative Products
Mar. 11, 2025: CBP Guidance on Duties on Imports of Aluminum and Aluminum Derivative Products
Mar. 11, 2025: Canadian 50% Steel & Aluminum Tariff Reportedly Averted
Mar. 11, 2025: Steel & Aluminum Derivatives Tariffs Outside Chapters 73 & 76 Effective This Week
Mar. 10, 2025: USTR Announces 2025 Trade Agenda
Mar. 6, 2025: Tariff Exemptions on Mexican USMCA Imports Reported
Mar. 6, 2025: All USMCA Imports Reportedly Exempt from Tariffs
Mar. 6, 2025: USMCA Tariff Exemption Executive Orders Published
Mar. 5, 2025: Senators Revise Plan to Tie Duties to Carbon Emissions
Mar. 5, 2025: Tariffs on Autos Under USMCA from Canada or Mexico Reportedly Suspended One Month
Feb. 4, 2025: Steel and Aluminum: The Gifts That Keep on Giving
Mar. 3, 2025: Timber, Lumber, and Derivatives Get Their Own National Security Investigation
Mar. 3, 2025: Canada and Mexico Duties Deadlines Arrive with No Indications of Delay
Feb. 28, 2025: Trump Indicates Likely March 4, 2025 Duty Increases
Feb. 26, 2025: Updated Guidance on Additional Duties for Imports from China and Hong Kong
Feb. 26, 2025: Copper Gets Its Turn for National Security Treatment
Feb. 24, 2025: Indictments Handed Down in Export Scheme
Feb. 24, 2025: The Next Shoe to Drop? USTR Proposes Actions Against Chinese Ships
Feb. 18, 2025: Preliminary ITC AD/CVD Determinations on Erythritol
Feb. 13, 2025: Trump Announces Marching Order for "Reciprocal Tariffs"
Feb. 11, 2025: Important Changes to Steel and Aluminum Imports into the United States
Feb. 11, 2025: Details Regarding New Aluminum Tariffs
Feb. 7, 2025: Making Sense of the Trump Trade Agenda
Feb. 6, 2025: USTR Creates Supply Chain Uncertainty Related to Chinese-Origin Ships

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Jan. 22, 2025: Webinar: What We Know After the Inauguration
Sep. 9, 2024: McPherson to Co-Moderate Export Enforcement Discussion
Jun. 2, 2023: BRC and Attorneys Ranked in 2023 Chambers Guide
May 12, 2015: Partner Helena Sullivan Speaks at New York City Bar Association on OFAC Compliance
April 8, 2013: Barnes/Richardson Partner Quoted in Ria Novosti Article