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Thompson Hine LLP, a full-service business law firm with approximately 400 lawyers in 11 offices, was ranked number 1 in the category “Most innovative North American law firms: New working models” by The Financial Times and was 1 of 7 firms shortlisted for The American Lawyer’s inaugural Legal Services Innovation Award. The firm has been recognized by the National Law Journal as a Legal Technology Trailblazer and featured by Bloomberg for its innovative service delivery models, which drive accuracy and predictability. The firm’s commitment to innovation is embodied in Thompson Hine SmartPaTHTM – a smarter way to work – predictable, efficient and aligned with client goals. For more information, please visit ThompsonHine.com and ThompsonHine.com/SmartPaTH.

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The U.S. Department of the Treasury&rsquo;s Office of Foreign Assets Control (OFAC) has <a href="https://www.federalregister.gov/documents/2020/04/10/2020-07497/north-korea-sanctions-regulations">published amendments</a> <a href="https://www.federalregister.gov/documents/2020/04/10/2020-07497/north-korea-sanctions-regulations" target="_blank" rel="noopener noreferrer">in the Federal Register</a> to the North Korea Sanctions Regulations, 31 C.F.R. 510.101-.901 (NKSR), which became effective April 10, 2020. The new amendments incorporate into the NKSR certain provisions of the <a href="https://www.congress.gov/114/plaws/publ122/PLAW-114publ122.pdf" target="_blank" rel="noopener noreferrer">North Korea Sanctions and Policy Enhancement Act of 2016</a> (NKSPEA), as amended by the Countering America&rsquo;s Adversaries Through Sanctions Act of 2017 (CAATSA) and the National Defense Authorization Act for Fiscal Year 2020 (NDAA 2020). The amendments:
<ul>
<li>Expand the list of prohibited activity and transactions;</li>
<li>Add blocking and correspondent account sanctions provisions;</li>
<li>Add a new prohibition applicable to persons owned or controlled by a U.S. financial institution and established or maintained outside the United States;</li>
<li>Add new statutory exemptions relevant to certain newly added prohibitions;</li>
<li>Make technical and conforming edits to three definitions, including &ldquo;luxury goods&rdquo; and &ldquo;significant transactions;&rdquo;</li>
<li>Revise an interpretive provision; and</li>
<li>Update the authorities and delegation sections of the regulations.</li>
</ul>
On December 20, 2019, President Donald Trump&nbsp;&nbsp;signed into law the 2020 NDAA, which, among other things, amended the NKSPEA by adding new blocking and correspondent or payable-through account sanctions at sections 104(g), 201B, and 201C. These have been incorporated by OFAC into the NKSR as &nbsp;&sect; 510.201(a)(3)(vii) through (x). OFAC is also incorporating additional correspondent or payable-through account sanctions of section 201B of NKSPEA into &nbsp;&sect; 510.210(c) of the NKSR, and of section 201C into &sect; 510.214 of the NKSR.

OFAC Amends North Korea Sanctions Regulations