On October 22, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has issued full blocking sanctions on Open Joint Stock Company Rosneft Oil Company (“Rosneft”) and Lukoil OAO (“Lukoil”) pursuant to Executive Order 14024. This...
Trade Compliance
Cryptocurrency Compliance Lessons from ShapeShift’s OFAC Sanctions Violations
On September 20, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a settlement agreement with ShapeShift AG, which was formerly a prominent cryptocurrency exchange. The company agreed to pay $750,000 to settle its...
Reminder to file your 2025 Annual Report of Blocked Property With OFAC: Due date September 30, 2025
On September 15, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued its “Reminder to File the 2025 Annual Report of Blocked Property.” Entities or persons subject to the reporting requirement under 31 C.F.R. § 501.603 of the...
Fracht FWO Inc. Fined $1.6 million for ‘Reckless Disregard’ of OFAC Sanctions
On September 3, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a settlement agreement with Fracht FWO Inc. (“Fracht”) to settle apparent violations of multiple sanctions programs. Fracht, an international freight...
Quarterly Trade Compliance Update – July 2025
Each quarter, I send my clients a trade compliance update, highlighting important developments over the last few months and summarizing key points for important sanctions programs. In addition to a variety of ad hoc designations, below is a summary of key events this...
OFAC Fines Harman International $1.4 Million for Iran Sanctions Violations
On July 8, 2025, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a settlement with Harman International Industries, Inc. (“Harman”) for $1,454,145 to settle potential civil liabilities stemming from eleven apparent...





