Hrishikesh Hari

Hrishikesh Hari

Dechert LLP

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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

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

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

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

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

New OFAC Guidance on 50% Rule Expands Reach of US Sanctions

The U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) revised its guidance with respect to entities owned 50 percent or more in the aggregate by more than one blocked persons. The new guidance, issued on...more

8/18/2014 - Extraterritoriality Rules OFAC Russia Sanctions Ukraine

Additional US and EU Sanctions Imposed on Russia and the Russian Government Reaction

On July 16, 2014, the U.S. Government imposed additional sanctions against Russian and Ukrainian individuals and companies as a result of the ongoing crisis in Eastern Ukraine. In addition to adding five individuals and 11...more

7/18/2014 - EU Russia Sanctions US

BNP Paribas Agrees to Record Penalty for Violating US Sanctions Laws

On June 30, 2014, BNP Paribas SA (“BNPP”), the largest bank in France, pled guilty to conspiring to violate U.S. sanctions laws and agreed to pay a total of nearly $8.9 billion in criminal forfeiture and penalties to the U.S....more

7/2/2014 - Banks BNP Paribas Corporate Criminal Fines Enforcement Enforcement Actions Foreign Banks International Emergency Economic Powers Act Sanctions Trading with the Enemy Act

Latest Round of US and EU sanctions on Russia and the Russian Government Reaction

In response to recent events in Ukraine, the United States and European Union imposed yet another round of sanctions this week. In response, Russia is considering a number of countermeasures that may affect U.S. and EU...more

4/30/2014 - BIS EU Executive Orders Exports Licenses OFAC Russia Sanctions Ukraine Visas

US, EU and Russia Swap Sanctions

President Obama issued yet another new Executive Order (E.O.) blocking property of additional Russian persons the U.S. Government holds responsible for the situation in Ukraine on 20 March 2014. For its part, on 21 March...more

3/26/2014 - EU Foreign Policy Russia Sanctions Ukraine

US and EU Impose Additional Sanctions on Russia

The United States and the European Union imposed new targeted sanctions on Russian and Ukrainian political figures viewed as responsible for undermining Ukrainian sovereignty on 17 March 2014. Both the EU and U.S. have made...more

3/26/2014 - EU Foreign Policy Russia Sanctions Ukraine

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