Jeremy Zucker

Jeremy Zucker

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

Additional U.S. Sanctions Imposed on Russian and Ukrainian Persons, But No Significant Escalation

On July 30, 2015, the U.S. Government added dozens of Russian and Ukrainian individuals and entities to the Ukraine-related sanctions lists.1 U.S. officials have stated that these new additions are not an escalation of U.S....more

8/3/2015 - Minister of Foreign Affairs Retaliation Russia Sanctions SDN List SSI List U.S. Treasury Ukraine

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

Russia and Ukraine Sanctions - One Year On

The spring and summer of 2014 saw the United States and European Union impose a range of sanctions relating to Ukraine and Russia in response to the series of events leading to the fall of the Yanukovyich government in...more

6/29/2015 - Russia Sanctions Ukraine Ukraine Freedom Support Act

Commerce Department Extends Deadline for BE-10 Reports and Important Clarifications for Asset Managers and Insurance Companies

On Thursday, May 28, the Bureau of Economic Analysis (BEA) issued an automatic one month extension to all first time filers of the BE-10 Benchmark Survey of U.S. Direct Investment Abroad. The extension grant, coming one day...more

6/2/2015 - Asset Management BEA Bureau of Economic Analysis Foreign Investment Form BE-10 GAAP Insurance Companies U.S. Commerce Department

Non-U.S. Companies Should Use Caution When Investing in U.S. “Agricultural Land”

A non-U.S. company that buys or sells U.S. real estate that is or once was used for agricultural purposes may face reporting requirements in connection with such transactions. These reporting obligations might apply whether...more

5/26/2015 - Agricultural Land Failure-to-File Farms Non-US Entities Penalties Real Estate Investments Renewable Energy Reporting Requirements

New Reporting Requirements Regarding Foreign Investment and Ownership

This article originally was published in the Winter 2015 Edition of the Dechert Private Equity Newsletter but has been updated to reflect recent guidance from the U.S. Commerce Department’s Bureau of Economic Affairs (BEA) on...more

4/23/2015 - BEA Covered Transactions Filing Deadlines Foreign Direct Investment Foreign Investment Foreign Ownership Form BE-10 Form BE-13 Private Equity Private Equity Funds Reporting Requirements U.S. Commerce Department

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

President Obama Issues New Executive Order Authorizing Sanctions Against Cyber Attackers

President Obama issued an Executive Order (the “Order”) on April 1, 2015 that authorizes financial sanctions against certain “persons” (including both individuals and entities) designated by the Treasury Secretary to be...more

4/8/2015 - Barack Obama Cyber Attacks Cybersecurity Executive Orders Sanctions SDN List U.S. Treasury

Revision of UK Military List of Controlled Items

The list of military goods, software and technology that are subject to export controls has been revised on 24 March 2015. The changes have been made through the Export Control (Amendment) Order 2015 which replaces Schedule 2...more

4/3/2015 - Criminal Prosecution Export Controls Exports Licenses Military Goods Penalties Software Technology UK

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

New Reporting Requirements Regarding Foreign Investment and Ownership

With the globalization of the economy, most private equity funds are likely to own companies based in the United States that have operations or subsidiaries outside the United States, and/or have interests in non-U.S....more

2/13/2015 - BEA Foreign Direct Investment Foreign Investment Private Equity Funds Reporting Requirements

Overview of Compliance Concerns Raised by Recent U.S. SEC Whistleblower Developments

The recent release of the Securities and Exchange Commission’s (SEC) annual report to Congress on the Dodd-Frank Whistleblower Program highlights the growing reliance of U.S. Government authorities on whistleblowers to...more

12/30/2014 - Annual Reports Anti-Retaliation Provisions Dodd-Frank Internal Reporting SEC Whistleblower Awards Whistleblowers

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

Amendments to EU Sanctions against Russia

The EU adopted amendments to the current EU sanctions against Russia on 4 December 2014. These amendments are implemented via Council Regulation (EU) No 833/2014 (as amended) (“Regulation 833/2014”). They are intended to both...more

12/10/2014 - Banking Sector Defense Sector Energy Sector EU Export Controls Exports New Amendments Oil & Gas Russia Sanctions

EU Imposes Further Sanctions on Ukrainian Separatists

On 29 November 2014, the European Union (EU) published measures targeting additional individuals and organisations to be added to the scope of EU sanctions measures against Russia. These measures widen the EU sanctions in...more

12/2/2014 - Asset Freeze EU Russia Sanctions SDN 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

Novel U.S. and EU Sanctions Targeting Russian Financing Activities Raise Unique Compliance Considerations for Global Financial...

Since March 2014, the United States and European Union have imposed multiple rounds of sanctions restricting certain activities with Russian and Ukrainian individuals and companies as a result of the ongoing crisis in...more

10/16/2014 - EU Financial Instruments Russia Sanctions SSI List Ukraine

US and EU Impose Additional Sanctions on Russia

The United States and European Union implemented new sanctions against Russia on 12 September 2014 as a result of the ongoing crisis in Ukraine. While the new US and EU measures share many similarities, companies subject to...more

9/15/2014 - EU Russia Sanctions Ukraine

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

Russia Bans the Import of Certain Agricultural and Food Products from the US, EU, Canada, Australia, and Norway

In response to the recent round of sanctions and export restrictions imposed on Russia, Russian Federation President Putin signed a decree on 6 August 20141 (the “Decree”) effectively banning or limiting for a period of one...more

8/8/2014 - Australia Canada EU Foreign Policy Imports Norway Russia Sanctions

Additional EU Sanctions Imposed on Russia

The European Union announced its intention to adopt a broad package of trade and economic sanctions against Russia, targeting access to EU capital markets, defence exports, energy related equipment and technology and...more

8/1/2014 - Capital Markets Energy Sector EU Export Controls Exports Financial Institutions Oil & Gas Russia Sanctions

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