On the eve of the 2024 Group of Seven (G7) Leaders’ Summit, the United States imposed new sanctions and export control measures against Russia further targeting sanctions evaders and, for the first time, the Russian...more
6/19/2024
/ Asset Seizure ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
EU ,
Export Administration Regulations (EAR) ,
Export Controls ,
Financial Services Industry ,
Foreign Financial Institutions (FFI) ,
Information Technology ,
Infrastructure ,
International Securities Market (ISM) ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
SDN List ,
Software ,
UK
Key Takeaways -
- As FDI regimes proliferate and mature around the globe, governments are taking an ever-more expansive view of the concept of “national security” to include more than military and defense interests, which...more
5/14/2024
/ Australia ,
Belgium ,
China ,
Critical Infrastructure Sectors ,
Cross-Border Transactions ,
EU ,
Foreign Direct Investment ,
Foreign Investment ,
France ,
Germany ,
Investment ,
Investors ,
Ireland ,
Legislative Agendas ,
National Security ,
Regulatory Agenda ,
Russia ,
Singapore ,
UK ,
United States
On the second anniversary of the start of the war in Ukraine and in response to the death of activist Aleksey Navalny in a Russian prison, the United States, European Union, and United Kingdom, along with Australia and...more
3/4/2024
/ Asset Freeze ,
Australia ,
Bureau of Industry and Security (BIS) ,
Canada ,
China ,
Economic Sanctions ,
Energy Sector ,
EU ,
Export Controls ,
Financial Services Industry ,
India ,
Mining ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Transportation Industry ,
Turkey ,
UK ,
Ukraine ,
United Arab Emirates (UAE) ,
US State Departments
Throughout December, the United States, European Union, and United Kingdom adopted a series of new sanctions packages against Russia that are expansive and multilayered and pose additional compliance challenges.
The new...more
1/11/2024
/ Compliance ,
Economic Sanctions ,
EU ,
Exports ,
Financial Institutions ,
Financial Services Industry ,
Imports ,
Jurisdiction ,
Office of Foreign Assets Control (OFAC) ,
Oil Prices ,
Russia ,
SDN List ,
Software ,
U.S. Treasury ,
UK
The Biden Administration appears to be moving forward with plans to establish a mechanism through Executive Order to review outbound investments from the United States to protect U.S. national security.
Recent reporting...more
5/12/2023
/ Biden Administration ,
CFIUS ,
China ,
Executive Orders ,
FIRRMA ,
G7 ,
Investment ,
Jurisdictional Thresholds ,
National Security ,
Outbound Transactions ,
Russia ,
Supply Chain ,
U.S. Commerce Department ,
U.S. Treasury
In 2022, the US, UK and EU all escalated their sanctions enforcement rhetoric. For example, senior US enforcement officials went so far as to describe sanctions as “the new FCPA” (referring to the US. Foreign Corrupt...more
2/17/2023
/ Civil Sanctions ,
Compliance ,
Economic Sanctions ,
Enforcement ,
EU ,
Liability ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Policies and Procedures ,
Russia ,
UK ,
Ukraine
Since February 2022, the United States, United Kingdom, and European Union have imposed unprecedented economic sanctions on Russia and various Russian entities and individuals in response to the war in Ukraine.
Actions have...more
12/19/2022
/ Asset Freeze ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement ,
EU ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Investment ,
Good Faith ,
Imports ,
Maritime Transport ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Popular ,
Russia ,
Safe Harbors ,
SDN List ,
U.S. Treasury ,
UK ,
Ukraine
Key Takeaways -
The U.S. Congress (“Congress”) is considering the establishment of a new Committee on National Critical Capabilities (“CNCC”) to review and potentially mitigate or block outbound investments from the United...more
At a New York City Bar Association event on April 27, Deputy Attorney General Lisa Monaco described economic sanctions as “the new FCPA.” Her characterization should put corporate compliance departments on notice. ...more
5/6/2022
/ Anti-Corruption ,
Compliance Management Systems ,
Corruption ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
FCPA Guidance ,
Foreign Corrupt Practices Act (FCPA) ,
Internal Controls ,
Military Conflict ,
Policies and Procedures ,
Russia ,
Ukraine ,
White Collar Crimes
Russia continues to introduce restrictive and other measures following the imposition of sanctions by the USA, EU, UK and other countries on Russia....more
3/14/2022
/ Counter Sanctions ,
Debt ,
Economic Sanctions ,
Financial Transactions ,
Foreign Corporations ,
Foreign Persons ,
Foreign Policy ,
Foreign Relations ,
Information Technology ,
International Trade ,
Russia ,
Ukraine
In response to the economic sanctions and export controls imposed on Russia by the US, EU, UK and other major economies, Russia imposed measures and countermeasures....more
Background As noted in our prior update, the United States, European Union and United Kingdom imposed a number of sanctions in connection with Russia’s recognition of the Donetsk and Luhansk regions of Ukraine. ...more
2/28/2022
/ Asset Freeze ,
Biden Administration ,
Economic Sanctions ,
EU ,
Export Controls ,
Financial Transactions ,
Foreign Policy ,
Foreign Relations ,
Foreign Trade Regulations ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
UK ,
Ukraine ,
Vladimir Putin
Russia's Actions -
On February 21, 2022, Russian President Vladimir Putin signed two executive orders recognizing the DNR/LNR Regions as “sovereign and independent states.”...more
2/23/2022
/ Biden Administration ,
Blocked Person ,
Critical Infrastructure Sectors ,
Economic Sanctions ,
Enforcement Priorities ,
Export Controls ,
Financial Transactions ,
Foreign Policy ,
Foreign Relations ,
Foreign Trade Regulations ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Ukraine ,
Vladimir Putin
As concerns continue to build between Russia and the West over the situation in Ukraine, the United States, the European Union, and the United Kingdom are preparing measures that could be utilized if diplomacy is...more
The United States, Russia, the North Atlantic Treaty Organization (“NATO”) and the Organization for Security and Co-operation in Europe (“OSCE”) held a series of talks this week aimed at de-escalating the situation at the...more
1/14/2022
/ CAATSA ,
Economic Sanctions ,
Financial Services Industry ,
Financial Transactions ,
Foreign Policy ,
International Relations ,
Legislative Agendas ,
NATO ,
Proposed Legislation ,
Regulatory Agenda ,
Russia ,
SDN List ,
Sovereign Debt ,
SWIFT ,
Ukraine ,
US Trade Policies
On April 15, 2021, the United States imposed new sanctions expanding restrictions on the purchase of certain Russian sovereign debt and other financing instruments and adding numerous Russian entities and individuals to the...more
Executive Summary - On March 2, 2021, the Biden Administration, in a coordinated announcement by the U.S. Departments of Treasury, State, and Commerce, tightened export restrictions against Russia and imposed sanctions and...more
3/4/2021
/ Biden Administration ,
Chemical Weapons ,
EU ,
Export Controls ,
Exports ,
Global Human Rights Sanctions Regime ,
Human Rights ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanctions ,
UK
On April 28, 2020, the Commerce Department’s Bureau of Industry and Security (“BIS”) published two final rules and one proposed rule targeting national security controlled exports and reexports to China, Russia, and...more
4/30/2020
/ Bureau of Industry and Security (BIS) ,
China ,
Commerce Control List ,
ECCNs ,
End-Users ,
Exemptions ,
Export Controls ,
Exports ,
Final Rules ,
Licensing Rules ,
Military End Use ,
National Security ,
Reporting Requirements ,
Russia ,
U.S. Commerce Department ,
US Trade Policies ,
Venezuela
The U.S.Treasury Department’s Office of Foreign Assets Control (“OFAC”) added Rosneft Trading SA (“Rosneft Trading”), a subsidiary of Russian oil major Rosneft Oil Company (“Rosneft”), to the List of Specially Designated...more
2/25/2020
/ Crude Oil ,
Debt Instruments ,
Economic Sanctions ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Risk Assessment ,
Russia ,
Sanction Violations ,
SDN List ,
Secondary Sanctions ,
SSI List ,
U.S. Treasury ,
Venezuela ,
Winding Down
The U.S. State and Treasury Departments announced that a second round of sanctions will be imposed against Russia pursuant to the Chemical and Biological Weapons Control Act of 1991 (“CBW Act”). The most notable new measure...more
8/7/2019
/ Bank of Russia ,
Biological-Weapons ,
Bond Markets ,
Broker-Dealer ,
CBW Act ,
Chemical Weapons ,
Commodities Traders ,
Commodity Futures Contracts ,
Economic Sanctions ,
Financial Institutions ,
Foreign Banks ,
International Banks ,
Investment Companies ,
National Security ,
Open General Export Licences (OGELs) ,
Russia ,
Secondary Sanctions ,
Trump Administration ,
U.S. Treasury ,
US State Departments
On April 25, 2019, Haverly Systems, Inc. (Haverly) agreed to pay a penalty of $75,375 to the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) to settle charges related to two violations of sanctions...more
4/30/2019
/ Compliance ,
Corporate Counsel ,
Economic Sanctions ,
Enforcement Actions ,
Goods or Services ,
Office of Foreign Assets Control (OFAC) ,
Payment Terms ,
Penalties ,
Russia ,
Sanction Violations ,
SSI List
Last week, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”), the EU Council, and Canada imposed further sanctions targeting Russian individuals and entities allegedly involved in the escalation of...more
3/22/2019
/ Australia ,
Banks ,
Blocked Entities ,
Blocked Person ,
CAATSA ,
Canada ,
CBW Act ,
Economic Sanctions ,
EU Council of Ministers ,
Executive Orders ,
Legislative Agendas ,
Liquid Natural Gas ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Popular ,
Russia ,
SDN List ,
Ukraine ,
US State Departments ,
Venezuela
On August 24, 2018, the U.S. Department of State announced a new but limited export licensing policy for defense and national security-sensitive goods and technology to Russia, effective August 27, 2018. The export licensing...more
8/27/2018
/ Chemical Weapons ,
Economic Sanctions ,
Export Controls ,
Exports ,
Financial Institutions ,
Foreign Exchanges ,
Foreign Subsidiaries ,
Government Officials ,
Legislative Agendas ,
National Security ,
Russia ,
State-Owned Enterprises ,
UK ,
US State Departments
International sanctions are a major compliance challenge for companies worldwide. The regulatory risks associated with economic sanctions, asset-freezing measures and trade embargoes are not new, but they continue to grow in...more
7/19/2018
/ Blocking Statutes ,
Bonds ,
Cryptocurrency ,
Debt Buyers ,
Debt-Equity ,
Defense Sector ,
Economic Sanctions ,
Energy Sector ,
EU ,
Financial Markets ,
General Licenses ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Popular ,
Russia ,
SDN List ,
Secondary Sanctions ,
Syria ,
Trump Administration ,
Ukraine ,
Venezuela
The Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury issued updated general licenses and related guidance in connection with sanctions imposed in April on certain Russian individuals and entities...more