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Trade Compliance

Quarterly Trade Compliance Update – November 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. If you would like to be added to the distribution list, please email me at...

Navigating OFAC Sanctions Risks From North Korean Remote Workers

With the continued rise in remote work, companies now face a unique vector for potentially significant sanctions risks that continues to catch even the most vigilant companies off guard.  This threat comes from the Democratic People's Republic of Korea “DPRK” or...

OFAC Increases Sanctions on Rosneft and Lukoil, Adding Both to the SDN List

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...