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
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
Tornado Cash, a cryptocurrency mixer, recently suffered two major setbacks in federal regulatory efforts to block its use and prosecute its founders.
First, a federal district court threw out a lawsuit challenging the...more
9/11/2023
/ Cryptocurrency ,
Cyber Crimes ,
Decentralized Autonomous Organization (DAO) ,
Department of Justice (DOJ) ,
Foreign Entities ,
International Emergency Economic Powers Act (IEEPA) ,
Money Laundering ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Regulatory Standards ,
Sanction Violations ,
SDN List ,
State Sponsors of Cyberattacks ,
U.S. Treasury
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
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
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
The U.S.-China trade war continues to escalate, most recently fueled by U.S. concerns over China’s assertion of increasing authority over Hong Kong. The U.S. and Chinese governments have exchanged jabs through the use of...more
7/17/2020
/ CFIUS ,
China ,
Criminal Prosecution ,
Economic Sanctions ,
Exceptions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Free Speech ,
Free Trade Agreements ,
Freedom of the Press ,
Hong Kong ,
Hong Kong Autonomy Act (HKAA) ,
Human Rights ,
Open General Export Licences (OGELs) ,
Popular ,
Revocation ,
Right to Peaceful Assembly ,
SDN List ,
Section 301 ,
Tariffs ,
Technology Sector ,
Trade Act of 1974 ,
Trade Policy ,
Trade Wars ,
Travel Ban ,
Trump Administration ,
United States
On February 1, 2019, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued guidance in the form of Frequently Asked Questions (“FAQs”) relating to sanctions imposed on January 28, 2019 against...more
2/4/2019
/ Blocked Person ,
Bonds ,
Derivatives ,
Due Diligence ,
Economic Sanctions ,
General Licenses ,
Non U.S. Person ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
SDN List ,
Trump Administration ,
U.S. Treasury ,
Venezuela ,
Winding Down
On January 28, 2019, the United States imposed blocking sanctions on Petróleos de Venezuela SA (“PdVSA”), the Venezuelan state-owned oil company. The measures follow President Trump’s recent decision to recognize Juan Guaidó,...more
1/31/2019
/ Blocked Person ,
Economic Sanctions ,
Energy Sector ,
Executive Orders ,
Financial Institutions ,
Foreign Investment ,
Imports ,
International Emergency Economic Powers Act (IEEPA) ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Presidential Elections ,
SDN List ,
Trump Administration ,
Venezuela ,
Winding Down
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 U.S. government has recently been active with respect to regulating cryptocurrencies. For its part, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) recently released guidance—issued in the form of...more
4/9/2018
/ Bitcoin ,
Cryptocurrency ,
Economic Sanctions ,
ETFs ,
Executive Orders ,
Hackers ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Venezuela ,
Virtual Currency
The United States announced new sanctions against the Venezuelan Government on August 25, 2017 that target the government’s ability to access U.S. debt and equity markets. The measures are intended to pressure Venezuelan...more
8/30/2017
/ Debt Instruments ,
Debt-Equity ,
Economic Sanctions ,
Executive Orders ,
Exports ,
General Licenses ,
Human Rights ,
Imports ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
SSI List ,
Trump Administration ,
Venezuela
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
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
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
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
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
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