New rules significantly expand the scope of existing Ukraine- and Russia-related sanctions and impose stringent export controls on Russia.
This Client Alert is published in the context of fast-moving developments....more
2/25/2022
/ Belarus ,
Biden Administration ,
Blocked Person ,
Economic Sanctions ,
EU ,
Financial Institutions ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Pipelines ,
Russia ,
SDN List ,
Ukraine
The decision clarifies the role of the English courts and the UK executive branch in the recognition of foreign heads of state and the ability of English courts to adjudicate the lawfulness of executive and legislative acts...more
The court explains how the controversial EU law operates to bar EU persons from complying with US sanctions on Iran and Cuba.
On 21 December 2021, the Court of Justice of the European Union (CJEU) released its long-awaited...more
The regulations will enable the UK government to impose sanctions in response to serious corruption around the world. On 26 April 2021, the United Kingdom implemented the Global Anti-Corruption Sanctions Regulations 2021 (the...more
The new rules are set to go in effect when the UK leaves the European Union on 31 December at 11 p.m. GMT.
The United Kingdom’s transition period for withdrawing from the European Union is scheduled to end on 31 December...more
Counsel and arbitrators give their take on why Hong Kong remains a world class arbitral seat of choice.
Key Points:
..Hong Kong courts continue to be independent and take a pro-arbitration and pro-enforcement approach...more
The decision confirms that the UK government can recognise one person as de jure head of state of a foreign state and implicitly recognise another person as the de facto head of state.
The English Court of Appeal’s recent...more
The UK imposes travel bans and financial sanctions on eight Belarusian officials - including Belarus’ President.
On 29 September 2020, the United Kingdom imposed sanctions on eight Belarusian officials it considers to have...more
The discontinuation of LIBOR in 2022 may pose a risk to arbitration proceedings. Preparation is key to a smooth transition.
Key Points:
..LIBOR, which is widely used in financial transactions and is embedded in many...more
The regulations will enable the UK government to sanction persons “involved” in human rights abuses — potentially anywhere in the world.
On 6 July 2020, the UK Foreign Secretary announced the introduction of the Global...more
The Court of Appeal decision, which considered standard form wording and the “mandatory” nature of US sanctions laws, upholds a High Court ruling exempting a borrower’s non-payment of interest, albeit on different...more
The penalty reflects the increasingly active approach in the UK to the enforcement of sanctions breaches.
The UK’s financial sanctions regulator, HM Treasury’s Office of Financial Sanctions Implementation (OFSI), has...more
The revised policy both clarifies and expands DOJ’s prior disclosure guidance.
On December 13, 2019, the United States Department of Justice (DOJ) revised its policy regarding voluntary self-disclosures (VSDs) of...more
In a geopolitically significant case, the English High Court opined on important provisions of the EU sanctions regime.
The judgment of the English High Court in Ministry of Defence & Support for Armed Forces of the...more
High Court ruling acknowledges the extraterritorial effect of US secondary sanctions.
In the recent case of Lamesa Investments Ltd v. Cynergy Bank Ltd [2019] EWHC 1877 (Comm), the High Court found that US secondary...more
New restrictions prohibit dealings between US persons and the Government of Venezuela.
On August 5, 2019, President Trump issued Executive Order (E.O.) 13884, entitled “Blocking the Property of the Government of...more
BIS designates Huawei Technologies Co., Ltd. and certain of its affiliates to the Entity List, restricting their ability to receive US products, software, and technology.
On May 16, 2019, the US Commerce Department’s...more
5/24/2019
/ Bureau of Industry and Security (BIS) ,
Cybersecurity ,
Economic Sanctions ,
Entity List ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
General Licenses ,
Huawei ,
Telecommunications ,
U.S. Commerce Department
OFAC outlines baseline considerations for evaluating a risk-based sanctions compliance program.
On May 2, 2019, the US Treasury Department’s Office of Foreign Assets Control (OFAC) published A Framework for OFAC Compliance...more
5/9/2019
/ Audits ,
Black & Decker ,
Chief Compliance Officers ,
Compliance ,
Corporate Counsel ,
Corporate Management ,
Economic Sanctions ,
Enforcement Actions ,
Internal Controls ,
Office of Foreign Assets Control (OFAC) ,
Risk Assessment ,
Training
Trump Administration breaks with precedent to allow US plaintiffs to bring “trafficking” suits under Title III of the Helms-Burton Act.
Title III of the Helms-Burton Act (the Cuban Liberty and Democratic Solidarity...more
Withdrawal from the Iran nuclear agreement triggers full implementation of US sanctions, including threat of “secondary” sanctions on non-US persons dealing with Iran.
As reported in the Latham Client Alert dated May 10,...more
11/6/2018
/ Economic Sanctions ,
EU ,
Financial Institutions ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
General Licenses ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Secondary Sanctions ,
Trump Administration
In light of the EU’s recent amendments to its long-standing blocking measure, EU operators will need to weigh the consequences of failing to comply with their contradicting obligations under US and EU law.
How has the EU...more
Withdrawal from the JCPOA will lead to re-imposition of several categories of US sanctions.
On May 8, 2018, President Trump announced that the United States will withdraw from the Joint Comprehensive Plan of Action...more
The new designations of Russian individuals and entities broadly expand the scope and impact of sanctions.
Background -
On April 6, 2018, the US Treasury Department’s Office of Foreign Assets Control (OFAC) added more...more
4/13/2018
/ Blocked Person ,
CAATSA ,
Economic Sanctions ,
Executive Orders ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Secondary Sanctions ,
Trump Administration ,
U.S. Treasury ,
Ukraine
The new designations of Russian individuals and entities broadly expand the scope and impact of sanctions.
Background -
On April 6, 2018, the US Treasury Department’s Office of Foreign Assets Control (OFAC) added more...more
4/10/2018
/ Blocked Person ,
CAATSA ,
Economic Sanctions ,
Executive Orders ,
Financial Institutions ,
General Licenses ,
Government Officials ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
State-Owned Enterprises ,
Trump Administration ,
U.S. Treasury
CJEU ruling on the incompatibility of a BIT provision with EU law may have implications for existing intra-EU BITs.
Key Points:
..The CJEU’s decision differs from Advocate-General Melchior Wathelet’s 2017 Opinion and...more