Darshak Dholakia

Darshak Dholakia

Dechert LLP

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United States Further Eases Economic Sanctions on Burma/Myanmar

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) eased certain sanctions against Burma/Myanmar on May 17, 2016, including by allowing most transactions involving Burmese financial institutions....more

5/19/2016 - Burma Economic Sanctions Financial Institutions General Licenses Myanmar OFAC SDN List US Department of State

Foreign Financial Institutions Beware: United States Expands Economic Sanctions Against Hizballah

Effective April 16, 2016, the United States will implement sanctions pursuant to the Hizballah International Financing Prevention Act of 2015. The new sanctions target Hizballah (or Hezbollah) and non-U.S. persons who support...more

4/18/2016 - Criminal Penalties Economic Sanctions Foreign Financial Institutions (FFI) Hizballah OFAC SDN List

US Commerce and Treasury Departments Further Ease Restrictions Against Cuba

The U.S. Commerce and Treasury Departments announced on January 26, 2016, actions to ease certain restrictions on transactions involving Cuba. The new actions do not significantly expand the types of activities in which U.S....more

1/27/2016 - Air Carriers Corporate Counsel Cuba Embargo Export Controls Financing Sanctions Travel Restrictions

Iran Sanctions: What is Prohibited or Licensable for EU Businesses?

Despite the easing of sanctions on Iran on 16 January under the Joint Comprehensive Programme of Action (JCPOA), some prohibitions and licensing requirements continue to apply to EU businesses. These are summarised below,...more

1/19/2016 - Dual Use Goods EU Exports Imports Iran Sanctions Joint Comprehensive Plan of Action (JCPOA) Licenses Military End Use Military Goods Nuclear Power Procurement Guidelines UN Security Council

Implementation Day: Iran Sanctions Eased Today

On Saturday, 16 January 2016, the International Atomic Energy Association (IAEA) submitted a report to the United Nations Security Council (UNSC) certifying that Iran has satisfied its obligations under the Joint...more

1/18/2016 - Implementation Day International Atomic Energy Agency Iran Sanctions Joint Comprehensive Plan of Action (JCPOA) SDN List Subsidiaries UN Security Council

Iran Sanctions: Early Easing of Sanctions Increasingly Possible

Public officials from the United States increasingly are making public statements regarding the likelihood that “Implementation Day” – the day on which many US and EU sanctions against Iran will be eased – will arrive in the...more

1/6/2016 - EU Implementation Day International Atomic Energy Agency Iran Sanctions Joint Comprehensive Plan of Action (JCPOA) Nuclear Power OFAC UK

Adoption Day in Iran Sanctions Deal: US and EU Give Clarification, But No Lifting of Sanctions Yet

The United States and European Union took preparatory steps on 18 October 2015 to begin fulfilling their commitments to suspend certain sanctions against Iran pursuant to the Joint Comprehensive Plan of Action (“JCPOA”)...more

10/22/2015 - Adoption Day Amending Regulation EU Financial Transactions Implementation Day Insurance Litigation International Atomic Energy Agency Iran Sanctions Joint Comprehensive Plan of Action (JCPOA) Metals Military Goods Nuclear Power OFAC Oil & Gas SDN List Shipping UN Security Council

U.S. Government Takes Steps to Further Ease Restrictions on Cuba

U.S. Commerce and Treasury Department measures intended to further ease existing export and sanctions restrictions regarding Cuba took effect on September 21, 2015. These amendments to the Cuban Assets Control Regulations...more

9/28/2015 - Cuba Cuban Assets Control Regulations (CACR) Export Administration Regulations Export Controls Internet Telecommunications Trade Restrictions U.S. Commerce Department U.S. Treasury

Iran Deal “Clears” Congress, But No Sanctions Relief Yet

On September 10, 2015, Senate Democrats in the U.S. Congress blocked a vote on a widely anticipated resolution to reject the Joint Comprehensive Plan of Action (“JCPOA”) regarding Iran’s nuclear program. On September 11, the...more

9/14/2015 - Adoption Day Asset Freeze EU Implementation Day Iran Iran Sanctions Joint Comprehensive Plan of Action (JCPOA) Nuclear Power Nuclear Weapons Political Parties UN Security Council United Nations

US Imposes Significant Export Restrictions on Russian Oil and Gas Field

The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) added the Yuzhno-Kirinskoye Field, a Russian oil and gas field, to the Entity List on August 7, 2015. The action effectively prohibits all persons from...more

8/13/2015 - BIS Blocked Person Export Administration Regulations Exports OFAC Oil & Gas Russia Sanctions SDN List U.S. Commerce Department

Additional U.S. Sanctions Imposed on Russian and Ukrainian Persons, But No Significant Escalation

On July 30, 2015, the U.S. Government added dozens of Russian and Ukrainian individuals and entities to the Ukraine-related sanctions lists.1 U.S. officials have stated that these new additions are not an escalation of U.S....more

8/3/2015 - Minister of Foreign Affairs Retaliation Russia Sanctions SDN List SSI List U.S. Treasury Ukraine

Nuclear Agreement with Iran Announced: Significant Easing of Iran Sanctions in Sight, but Only Outside of the United States

Iran and the P5+1 countries (United States, Russia, China, United Kingdom, France and Germany) on 14 July 2015 announced their agreement on a comprehensive plan under which certain international sanctions against Iran will be...more

7/15/2015 - International Atomic Energy Agency Iran Iran Sanctions Joint Comprehensive Plan of Action (JCPOA) Nuclear Power Nuclear Weapons P5+1 Nations United Nations

Russia and Ukraine Sanctions - One Year On

The spring and summer of 2014 saw the United States and European Union impose a range of sanctions relating to Ukraine and Russia in response to the series of events leading to the fall of the Yanukovyich government in...more

6/29/2015 - Russia Sanctions Ukraine Ukraine Freedom Support Act

Commerce Department Extends Deadline for BE-10 Reports and Important Clarifications for Asset Managers and Insurance Companies

On Thursday, May 28, the Bureau of Economic Analysis (BEA) issued an automatic one month extension to all first time filers of the BE-10 Benchmark Survey of U.S. Direct Investment Abroad. The extension grant, coming one day...more

6/2/2015 - Asset Management BEA Bureau of Economic Analysis Foreign Investment Form BE-10 GAAP Insurance Industry U.S. Commerce Department

New Reporting Requirements Regarding Foreign Investment and Ownership

This article originally was published in the Winter 2015 Edition of the Dechert Private Equity Newsletter but has been updated to reflect recent guidance from the U.S. Commerce Department’s Bureau of Economic Affairs (BEA) on...more

4/23/2015 - BEA Covered Transactions Filing Deadlines Foreign Direct Investment Foreign Investment Foreign Ownership Form BE-10 Form BE-13 Private Equity Private Equity Funds Reporting Requirements U.S. Commerce Department

FLIR FCPA Action Highlights: Continued Focus on Penalizing Improper Expenditures for Government Officials

FLIR Systems, Inc. (“FLIR”), a publicly traded company based in Oregon, agreed to pay approximately $9.5 million to settle allegations of violations of the Foreign Corrupt Practices Act (“FCPA”) on April 8, 2015. The U.S....more

4/15/2015 - Compliance Corporate Gifts Disgorgement DOJ FCPA FLIR System Government Officials Internal Controls Saudi Arabia SEC Self-Reporting Settlement Training

President Obama Issues New Executive Order Authorizing Sanctions Against Cyber Attackers

President Obama issued an Executive Order (the “Order”) on April 1, 2015 that authorizes financial sanctions against certain “persons” (including both individuals and entities) designated by the Treasury Secretary to be...more

4/8/2015 - Barack Obama Cyber Attacks Cybersecurity Executive Orders Sanctions SDN List U.S. Treasury

U.S. Government Announces Significant Sanctions Enforcement Actions Against Schlumberger and PayPal

The U.S. Government announced two major sanctions enforcement actions this week that reinforce the compliance challenges faced by both U.S. companies with international activities and non-U.S. companies subject to U.S....more

3/30/2015 - Civil Monetary Penalty Compliance Criminal Penalties DOJ Enforcement Actions Guilty Pleas International Emergency Economic Powers Act Iran Sanctions OFAC PayPal Sanctions Schlumberger Settlement Sudan

CFIUS Releases Annual Report to Congress

The Committee on Foreign Investment in the United States (CFIUS) was established decades ago to identify and recommend responses to threats to US national security posed by acquisitions by non-US entities of controlling...more

3/16/2015 - Acquisitions CFIUS Divestiture FINSA Foreign Investment Interstate Commerce National Security Voluntary Withdrawal

New Reporting Requirements Regarding Foreign Investment and Ownership

With the globalization of the economy, most private equity funds are likely to own companies based in the United States that have operations or subsidiaries outside the United States, and/or have interests in non-U.S....more

2/13/2015 - BEA Foreign Direct Investment Foreign Investment Private Equity Funds Reporting Requirements

Overview of Compliance Concerns Raised by Recent U.S. SEC Whistleblower Developments

The recent release of the Securities and Exchange Commission’s (SEC) annual report to Congress on the Dodd-Frank Whistleblower Program highlights the growing reliance of U.S. Government authorities on whistleblowers to...more

12/30/2014 - Annual Reports Anti-Retaliation Provisions Dodd-Frank Internal Reporting SEC Whistleblower Awards Whistleblowers

US and Cuba Seek to Normalize Relations; US to Ease Certain Restrictions

President Obama announced on December 17, 2014 that the United States and Cuba will open talks seeking to restore full diplomatic relations, and that the United States will be taking a number of steps to ease restrictions in...more

12/18/2014 - Barack Obama Cuba Foreign Relations

New Law Significantly Expands Legal Basis for US Sanctions Against Russia

On 16 December 2014, President Obama announced that he will sign the Ukraine Freedom Support Act of 2014 (hereinafter the “Act”) into law. As discussed in our update dated 12 December 2014, the Act represents a potentially...more

12/18/2014 - Banking Sector Defense Sector Energy Sector FFI New Legislation OFAC Russia Sanctions Ukraine

US Clarifies Sanctions Provisions and US Senate Passes a Bill to Codify and Expand Sanctions

As noted in previous updates, the United States and European Union continue to impose sanctions against Ukrainian and Russian individuals and entities as a result of the turmoil in Ukraine. On 11 December 2014, the US Senate...more

12/14/2014 - Banking Sector Defense Sector Energy Sector OFAC Oil & Gas Russia Sanctions SDN List SSI List Ukraine

Temporary Suspension of Certain Sanctions Against Iran Extended Until Mid-2015

On November 24, 2014, the United States, the United Kingdom, France, China, Russia and Germany (collectively, the “P5+1”) announced that they will continue current negotiations with Iran regarding its nuclear program and will...more

11/26/2014 - Extensions Iran Sanctions JPOA P5+1 Nations

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