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
President Trump announced today, May 8, 2018, that the United States would withdraw from the Joint Comprehensive Plan of Action (“JCPOA”), the Iran nuclear deal implemented in January 2016. In connection with the...more
Yesterday, President Trump signed H.R. 3364, the “Countering America’s Adversaries Through Sanctions Act,” enacting into law limited additional sanctions against Russia and, critically, restricting his ability to suspend or...more
After weeks of discussion and procedural uncertainty, the U.S. House of Representatives passed new legislation by a vote of 419–3 that, if enacted into law, will strengthen existing sanctions against Russia and also impose...more
7/29/2017
/ Congressional Authority ,
Cyber Attacks ,
Economic Sanctions ,
Energy Sector ,
Foreign Relations ,
Hackers ,
Iran ,
Iran Sanctions ,
North Korea ,
Pending Legislation ,
Russia ,
SSI List ,
Trump Administration
U.S. District Court Judge Richard M. Berman denied a motion to dismiss the indictment in the closely followed criminal prosecution of Reza Zarrab, a Turkish/Iranian businessman charged with conspiring to evade U.S. economic...more
10/20/2016
/ Banks ,
Blocked Entities ,
Criminal Conspiracy ,
Criminal Prosecution ,
Economic Sanctions ,
Evasion ,
Extraterritoriality Rules ,
Financial Transactions ,
Foreign Relations ,
Fraud ,
General Licenses ,
Indictments ,
International Emergency Economic Powers Act (IEEPA) ,
International Litigation ,
Iran Sanctions ,
ITSR ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Turkey
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
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
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
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 ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
SDN List ,
Shipping ,
UN Security Council
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
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
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 ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Guilty Pleas ,
International Emergency Economic Powers Act (IEEPA) ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
PayPal ,
Sanctions ,
Schlumberger ,
Settlement ,
Sudan
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