The Treasury Department has taken initial steps to implement the Trump administration’s “total elimination” policy directed at certain drug trafficking cartels. Most recently, on May 1, Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an alert advising about a rising trend of oil smuggling from Mexico across the U.S. border led by several cartels.
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What’s Happening?
Under the Department of Justice’s (DOJ) “Preventing Access to U.S. Sensitive Personal Data and Government-Related Data by Countries of Concern or Covered Persons” rules (the Rules), allowing access outside the United States to certain types of sensitive personal data involving “countries of concern” may be restricted or prohibited beginning on April 8. See our previous advisory for more detail.
We find ourselves in the midst of a raucous debate among sanctions practitioners about the impact of the Fifth Circuit’s recent decision upholding a challenge against the sanctions the Office of Foreign Assets Control (OFAC) imposed on Tornado Cash, a cryptocurrency “mixer.” Does this case presage a sea change in how OFAC’s sanctions will apply to new technologies that may not clearly fall within the bounds of the agency’s 1970s-era statutory authority? Or is the Fifth Circuit’s ruling likely to be overturned, merely a statement of the obvious, so unclear as to have minimal real world impacts, or otherwise just a blip in the decades-long trend of judicial deference to OFAC?
Days before President Biden leaves the White House, the U.S. government has delivered a major blow against Russia. On January 10, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced its most comprehensive sanctions to-date against Russia’s energy sector. OFAC’s sanctions were complemented by another sweeping sanctions action by the U.S. Department of State (State Department) on the same day.