The new Directive (EU) 2024/1226 defines criminal offences and penalties for breaches of EU sanctions. This Client Alert summarises key provisions and implications for businesses.
This Client Alert is published in the...more
The UK’s latest sanctions affect multiple areas and actors, including Turkish, Chinese, and Dubai-based entities alleged to support Russian military activities.
This Client Alert is published in the context of ongoing...more
The EU’s 12th and 13th “packages” of sanctions on Russia cancel a significant exemption, ban the provision of certain software systems, and impose multiple other measures.
This Client Alert is published in the context of...more
4/26/2024
/ Economic Sanctions ,
Enterprise Management Incentive (EMI) ,
EU ,
European Economic Area (EEA) ,
Exports ,
Foreign Nationals ,
Imports ,
Professional Services Contract ,
Russia ,
SaaS ,
Technology Sector
The new measures bar the import of iron or steel products processed in countries other than Russia but incorporating Russian-origin iron or steel components. The measures form part of a series of significant sanctions updates...more
A proposed rule would increase Treasury’s insight into non-US crypto mixing transactions to combat illicit activities by malicious actors.
On October 19, 2023, the US Department of the Treasury’s Financial Crimes...more
11/3/2023
/ Anti-Money Laundering ,
Blockchain ,
Cryptocurrency ,
Digital Assets ,
FinCEN ,
Market Participants ,
Money Laundering ,
NPRM ,
Patriot Act ,
Regulatory Oversight ,
Theft ,
U.S. Treasury
The new measures build on sweeping restrictions that the United States introduced in October 2022.
On October 17, 2023 — just over a year after introducing extensive regulations aimed at restricting parties in China from...more
10/31/2023
/ Bureau of Industry and Security (BIS) ,
China ,
Defense Sector ,
Entity List ,
Export Controls ,
Exports ,
Military End Use ,
National Security ,
Semiconductors ,
Technology Sector ,
U.S. Commerce Department
Trade-based money laundering (TBML) describes a set of techniques through which drug traffickers, terrorists and other criminals use the veneer of trade to move illicit funds across borders while disguising the origin and...more
10/16/2023
/ Anti-Money Laundering ,
BSA/AML ,
Criminal Conspiracy ,
Criminal Prosecution ,
Customs and Border Protection ,
Department of Justice (DOJ) ,
Drug Trafficking ,
Enforcement Actions ,
FinCEN ,
Indictments ,
International Trade ,
Law Enforcement ,
Money Laundering ,
Popular ,
re Grand Jury ,
Supply Chain ,
Terrorism Funding ,
Trade-Based Money Laundering
Companies that promptly self-disclose and remediate potential violations of administrative or criminal law may significantly mitigate liability.
On July 26, 2023, the US Departments of Justice (DOJ), Commerce, and the...more
8/3/2023
/ Bureau of Industry and Security (BIS) ,
Compliance ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Authority ,
Export Controls ,
Exports ,
Joint Policy Statements ,
Joint Statements ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanction Violations ,
Self-Reporting
New measures expand existing sanctions and export controls, including by restricting medical item exports and targeting Russia’s architecture and engineering sectors.
This Client Alert is published in the context of...more
The first-ever tri-seal Note highlights tactics used to circumvent Russia-related restrictions, while NSD adds 25 prosecutors focusing on sanctions and export controls.
In May 2022, shortly after hostilities in Ukraine...more
3/21/2023
/ Compliance ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Military Conflict ,
Risk Management ,
Russia ,
Sanction Violations ,
U.S. Commerce Department ,
U.S. Treasury ,
Ukraine
New announcements and rules expand the scope of existing sanctions and export controls on Russia.
This Client Alert is published in the context of ongoing developments and should be read in conjunction with the Latham’s...more
3/16/2023
/ Biden Administration ,
Blocked Person ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Embargo ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Financial Transactions ,
Foreign Policy ,
Foreign Relations ,
Foreign Trade Regulations ,
General Licenses ,
Infrastructure ,
Military Conflict ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Oil Prices ,
Pipelines ,
Russia ,
SDN List ,
Ukraine
The joint Strike Force will focus on shielding advanced US technology from nation-state adversaries and on prosecuting export controls violations.
On February 16, 2023, the US Departments of Justice and Commerce announced...more
The price cap operates as an exemption to the ban on transportation of Russian seaborne crude oil to other countries.
This Client Alert is published in the context of ongoing developments and should be read in conjunction...more
12/12/2022
/ Crude Oil ,
Economic Sanctions ,
EU ,
G7 ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Oil Prices ,
Russia ,
Safe Harbors ,
UK ,
Ukraine
The EU has issued its eighth “package” of sanctions measures on Russia. Meanwhile, US agencies have issued guidance on “secondary” sanctions enforcement, designated additional SDNs, and restricted further exports to Russia —...more
10/12/2022
/ Asset Freeze ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
EU ,
Export Controls ,
Exports ,
Foreign Policy ,
Foreign Relations ,
Imports ,
Military Conflict ,
Oil & Gas ,
Russia ,
SDN List ,
State-Owned Enterprises ,
Ukraine
Updated DOJ policies will continue to focus on individual accountability and corporate recidivism, while aiming to provide additional incentives for voluntary self-reporting, foster greater transparency on use of monitors,...more
9/28/2022
/ Compliance ,
Cooperation ,
Corporate Crimes ,
Corporate Misconduct ,
Corporate Officers ,
Criminal Investigations ,
Department of Justice (DOJ) ,
Foreign Corrupt Practices Act (FCPA) ,
New Guidance ,
Personal Liability ,
Voluntary Disclosure
The US Treasury opens a Pandora’s box of legal issues as it targets a decentralized finance protocol used for both licit and illicit means.
On August 8, 2022, the US Department of the Treasury’s Office of Foreign Assets...more
8/12/2022
/ Blockchain ,
Cryptocurrency ,
Decentralized Finance (DeFi) ,
Economic Sanctions ,
Ethereum ,
Foreign Policy ,
Money Laundering ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Ransomware ,
SDN List ,
U.S. Treasury
The EU’s “maintenance and alignment” sanctions target additional Russian persons, enhance existing sanctions, and implement new prohibitions - including on the import of Russian gold.
This Client Alert is published in the...more
The ban hits new investment in Russia and certain professional services, while also restricting imports of Russian oil, coal, and gold and exports of key industrial goods.
This Client Alert is published in the context of...more
The new measures against Russia’s ally largely parallel the UK’s sanctions against Russia itself.
This Client Alert is published in the context of ongoing developments and should be read in conjunction with Latham’s...more
The measures prohibit gold imports and add new SDN, Entity List, and asset freeze designations.
This Client Alert is published in the context of ongoing developments and should be read in conjunction with the Latham &...more
7/5/2022
/ Asset Freeze ,
Belarus ,
Belarus Sanctions ,
Biden Administration ,
Economic Sanctions ,
Export Controls ,
General Licenses ,
Japan ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Trade Restrictions ,
UK ,
Ukraine
OFAC has also extended certain general licenses, while BIS has continued to restrict exports to Russia.
This Client Alert is published in the context of ongoing developments and should be read in conjunction with the...more
The UK’s financial sanctions regulator has released new guidance in light of its additional powers to police sanctions breaches.
This Client Alert is published in the context of ongoing developments and should be read in...more
New announcements and rules expand the scope of existing sanctions and export controls on Russia and Belarus.
This Client Alert summarises the latest sanctions and trade restrictions that have been imposed, or are under...more
New rules and announcements expand existing sanctions and export controls relating to Russia.
This Client Alert is published in the context of ongoing developments and should be read in conjunction with the Latham &...more
5/16/2022
/ Biden Administration ,
Economic Sanctions ,
EU ,
Export Controls ,
Financial Transactions ,
Foreign Policy ,
General Licenses ,
Military Conflict ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
UK ,
Ukraine
New rules significantly expand the scope of existing sanctions and export controls on Russia.
This Client Alert is published in the context of ongoing developments and should be read in conjunction with the Latham &...more
4/13/2022
/ Asset Freeze ,
Belarus ,
Economic Sanctions ,
EU ,
Export Controls ,
Financial Crimes ,
Foreign Investment ,
General Licenses ,
Japan ,
Russia ,
Trade Relations ,
Trade Restrictions ,
UK ,
Ukraine