Jeremy Zucker

Jeremy Zucker

Dechert LLP

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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

Change to HM Treasury's policy in relation to receiving funds from an individual or entity subject to EU Sanctions

The UK HM Treasury (“HMT”) is changing its policy in relation to funds received in the UK that have come either directly or indirectly from an individual or entity outside of the EU that is subject to EU Sanctions (a...more

7/29/2014 - EU Frozen Assets Iran Sanctions UK

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

Suspension of Certain UK Export Licences for Exports to Russia

In the context of an EU-wide review of export licensing for Russia, the UK Foreign Secretary William Hague announced in March 2014 that the UK Government would be suspending (i) all existing export licences and application...more

6/12/2014 - Export Controls Exports Russia Sanctions UK

In First Ruling by a Court of Appeals, Eleventh Circuit Adopts Broad Definition of “Foreign Instrumentality” under FCPA

The Foreign Corrupt Practices Act (“FCPA”) prohibits bribing a “foreign official,” yet courts have rarely had the chance to weigh in on who exactly qualifies as a foreign official. Enforcement agencies have taken the position...more

5/23/2014 - Anti-Corruption Compliance FCPA Foreign Official Instrumentality

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

Russian Trade and Economic Sanctions Draw Even Closer

Trade and economic sanctions against Russia now look unavoidable unless diplomatic efforts can be revived. As such, it is now an important opportunity for companies to assess, and to start thinking about possible plans to...more

3/14/2014 - Asset Freeze EU Sanctions Ukraine

Two Non-U.S. Banks Agree to Pay Penalties Totaling $160 Million for Violations of U.S. Sanctions Laws Resulting from Omnibus...

Recent enforcement actions brought by the U.S. Government against non-U.S. banks for violations of U.S. sanctions laws demonstrate the need for financial institutions, particularly those that act as custodians or financial...more

1/30/2014 - Anti-Money Laundering Bank Secrecy Act Banks Compliance FinCEN Foreign Banks Iran ITSR OFAC Sanctions U.S. Treasury

Iranian Sanctions – Joint Action Plan is Implemented in EU

Background - Implementation of the Joint Action Plan agreed between the E3/EU+3 in October 2013 by suspending certain sanctions against Iran in relation to nuclear proliferation began on 20 January 2014. This...more

1/27/2014 - EU Iran Iran Sanctions Middle East Nuclear Power Oil & Gas

What's the One Thing Missing From Your Corporate Compliance Program?

What's the one thing missing from most corporate compliance programs? For a legal perspective, that's the question we put to corporate attorneys writing on JD Supra, asking each to commit to just one essential element...more

11/13/2013 - Chief Compliance Officers Compliance Corporate Culture Crisis Management Documentation DOJ Enforcement Actions Ethics FCPA Internal Controls Legal Perspectives Risk Management SEC

Export Control: Transparency in Export Licensing

The UK Government is determined to increase transparency and public accountability on export control issues. The Government's “Transparency Initiative” aims to make public, information regarding so-called “open” export...more

8/6/2013 - Export Controls Licenses Transparency UK

CIS Legal Update - May 2013: Measures Taken to Strengthen Russian Anti-Corruption Laws

Despite Russia’s reputation for corruption, the anti-bribery climate in Russia is evolving. A recent flurry of anti-bribery legislation, as well as Russia’s ratification of the OECD Convention on Combating Bribery of Foreign...more

5/14/2013 - Anti-Bribery Anti-Corruption Compliance Enforcement FCPA OECD Russia UK Bribery Act

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