Kirkland Alert Kirkland & Ellis LLP

Russia Sanctions Developments Highlight Need for Active Compliance Efforts

The U.S. Treasury Department's Office of Foreign Assets Control ("OFAC") has significantly expanded the number of entities and individuals subject to Russia sanctions and separately censured U.S. insurance and financial institution entities for failing to keep current with OFAC's sanctions list to prevent transactions with sanctioned parties. Economic sanctions continue to evolve as political situations change in the comprehensively sanctioned jurisdictions of Cuba, Crimea, Iran, North Korea, Sudan and Syria, as well as in countries targeted by more limited but often more complicated sanctions such as those relating to Russia, Burma/Myanmar and many other countries.