International Regulation and Compliance

On March 21, 2025,?the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced the?delisting?of Tornado Cash, a digital asset mixer, from the List of Specially Designated Nationals and Blocked Persons (SDN List). The Treasury Department said the delisting was “[b]ased on the Administration’s review of the novel legal and policy issues raised by use of financial sanctions against financial and commercial activity occurring within evolving technology and legal environments…” For more on the delisting of Tornado Cash, read our latest blog post: https://lnkd.in/eSvu9nFx

In this week's edition of the Sanctions Update, members of Steptoe's International Trade and Regulatory Compliance and Strategic Risk teams discuss the US Treasury's delisting of Tornado Cash, the recent UK-EU meeting on Russia, and other developments across the US, UK, and EU. Read the March 24, 2025 installment here: https://lnkd.in/ekE6JfcP

In this week's edition of the Sanctions Update, members of Steptoe's International Trade and Regulatory Compliance and Strategic Risk teams discuss new US sanctions on Iran, Hungary's agreement to renew EU sanctions on Russia, and other developments across the US, UK, and EU. Read the March 17, 2025 installment here: https://lnkd.in/g_GEW96f

On March 14, 2025, HM Treasury’s Office of Financial Sanctions Implementation (“OFSI”) published details of?an enforcement action for information offences against three charities?under the UK’s International Counter-Terrorism sanctions regime.?The enforcement action offers an important reminder to all companies of the breadth of their obligations under UK financial sanctions regulations and, in particular, the importance of implementing and communicating procedures to ensure the provision of timely responses to OFSI information requests. Steptoe's Alex Melia covers OFSI's recent enforcement action in a new blog post: https://lnkd.in/grKRun3J

In this week's edition of the Sanctions Update, members of Steptoe's International Trade and Regulatory Compliance and Strategic Risk teams discuss US sanctions against Russia, US agencies' targeting of alleged Chinese hackers, the UK's Syria sanctions regime, and other developments across the US, UK, and EU. Read the March 10, 2025 installment here: https://lnkd.in/ekde2Xed

In this week's edition of the Sanctions Update, members of Steptoe's International Trade and Regulatory Compliance and Strategic Risk teams discuss US sanctions against Iran, EU and UK sanctions against Russia, Congress's reaction to Thailand's forced return of Uyghurs to China, and other developments. Read the March 3, 2025 installment here: https://lnkd.in/eH7HpXgC

In response to the ongoing conflict in Ukraine, the European Council finally reached an agreement to introduce the European Union’s 16th sanctions package on 24 February 2025, targeting key sectors of the Russian economy. This comprehensive set of measures aims to further restrict Russia's economic capabilities and curtail its ability to finance the war. Steptoe's Renato Antonini, Eva Monard, Guy Soussan, and Elli Zachari analyze the EU's recent sanctions package in a new blog post: https://lnkd.in/ehkp6R45

In the weeks since his return to the White House, President Trump has renewed his “maximum pressure” campaign against Iran. The Trump administration's early actions suggest that it is likely to be more aggressive in its approach to implementing and enforcing existing sanctions against Iran under this policy. Read more about the "maximum pressure" campaign and possible areas for expansion or enforcement in a new blog post: https://lnkd.in/euhbQbDJ

On February 26, 2025, the Department for Business and Trade’s Export Control Joint Unit (“ECJU”) issued two new notices to exporters, which address the removal of Rwanda as a permissible destination under four Open General Export Licences (“OGELs”) relating to military goods and guidance as to how the ECJU assesses export licence applications involving Common High Priority List (“CHPL”) items included on the UK’s strategic export controls list. Steptoe's Alex Melia covers the UK's updated guidance in a new blog post: https://lnkd.in/e3qHhKG9

The Department of Commerce’s Bureau of Industry and Security (BIS) has been very active so far this year with respect to its Information and Communications Technology and Services (ICTS) authorities, issuing an advance notice of proposed rule on drones and a final rule on so-called “connected vehicles.” Although those actions were taken in the final days of the Biden administration, early signs suggest the Trump administration is likely to keep those rulemakings in place and target other industries for ICTS-based prohibitions or restrictions. Steptoe's Anjali Belur, Chris Forsgren, Tyler Evans, Brian Fleming, and Evan Abrams assess the ICTS rulemaking activity that has happened so far this year and explore what is likely to lie ahead under the Trump administration in a new blog post: https://lnkd.in/e_cJqgqw