OFAC Reinforces “Gatekeeper Liability” with High-Profile Russia-Related Penalties
OFAC has reinforced its willingness to target not only sanctioned persons but also intermediaries who enable them. Two recent enforcement matters highlight that even routine administrative services involving blocked persons can constitute prohibited dealings and lead to significant penalties.
U.S. Floats 28-Point Ukraine Peace Plan, Raising Questions Over Future of Russia Sanctions
The United States has circulated a 28-point peace proposal aimed at ending the war in Ukraine, triggering debate over territorial concessions, security arrangements, and the future of Western sanctions on Russia.
BIS Affiliates Rule – One-Year Suspension and Compliance Implications
The Affiliates Rule broadens U.S. export controls to foreign affiliates 50%-owned by listed entities, aligning BIS with OFAC’s 50 Percent Rule. Though implementation is suspended for one year, companies must prepare for strict ownership-based compliance once it takes effect.
OTSI Publishes Case Study on Suspected Trade Sanctions Breach
The U.K. OTSI released a case study on a suspected breach of Russia sanctions involving a multinational bank that facilitated trade-finance transactions linked to a designated entity. The report highlights screening failures, weak escalation, and gaps in ownership verification.