Pillar
OFAC & US Sanctions
OFAC enforcement, designations, general licenses, and US sanctions program updates.
The OFAC 50 Percent Rule: Sanctions Ownership and the 2026 Sham Transactions Guidance
A practitioner's guide to the OFAC 50 Percent Rule — ownership aggregation, indirect ownership, FAQ 401 examples, the March 2026 Sham Transactions Guidance, the GVA Capital, IPI Partners, and Gracetown enforcement actions, and the BIS Affiliates Rule taking effect November 10, 2026.
Blocking Reports vs. Voluntary Self-Disclosures: How OFAC's Two Reporting Tracks Interact
A practitioner's decision guide to the OFAC reporting requirements under §§ 501.603 and 501.604, the voluntary self-disclosure framework, and how the two tracks interact — with a quick-reference table, a two-track decision flow, and downloadable operational checklists.
Sberbank Sanctions: How the U.S. and E.U. Targeted Russia's Largest Bank
How the U.S. and E.U. coordinated to cut Russia's largest bank out of the global financial system — what was actually blocked, what wasn't, and what compliance teams should have learned.
How Switzerland and Japan are standing up to Russia’s invasion of Ukraine
Switzerland's break with neutrality and Japan's coordinated designations marked a shift in global sanctions enforcement against Russia. A look at how non-EU jurisdictions aligned with the OFAC and EU framework.
Understanding Administrative Sanctions: A Comprehensive Guide to Types and Consequences
A practitioner overview of administrative sanctions: the spectrum from civil money penalties through cease-and-desist orders, and the procedural rights that attach at each stage.