Everyone is doing their part during these unprecedented times to help the global community cope with the COVID-19 pandemic.  That includes the U.S. Office of the Foreign Assets Control (“OFAC”), in the Department of the Treasury.  In the past two weeks OFAC has issued two new guidance documents and several Frequently Asked Questions to point out that its softer, humanitarian side for exporters of medical and agricultural goods, and to suggest that it can be understanding regarding sanctions compliance issues … Read More

In recent years the United States’ aggressive use of economic sanctions and other trade restrictions has been rattling trade compliance managers and reshaping supply chains of large and small companies around the world.  Among the most consequential measures was the listing of the Chinese telecommunications giant Huawei and its subsidiaries world-wide on the U.S. Entity List.  Many companies have already re-adjusted their supply chains to respond to these disruptions, but it is likely that economic warfare through imposition of restrictions … Read More