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
President Biden recently signed into law the Foreign Extortion Prevention Act (“FEPA”), enabling federal prosecution of non-U.S. government officials who solicit or receive bribes.
FEPA complements the Foreign Corrupt...more
1/23/2024
/ Anti-Corruption ,
Anti-Money Laundering ,
Biden Administration ,
Bribery ,
Department of Justice (DOJ) ,
Economic Sanctions ,
FEPA ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Official ,
Securities Exchange Act of 1934 ,
Wire Fraud
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
The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) recently announced two settlements that underscore OFAC’s continued emphasis on companies developing and implementing effective, risk-based...more
In a recent judgment, the English High Court for the first time ruled on a sanctions de-listing case under Section 38 of the Sanctions and Anti-Money Laundering Act 2018 (“SAMLA”). Following the UK’s departure from the EU,...more
In 2022, the US, UK and EU all escalated their sanctions enforcement rhetoric. For example, senior US enforcement officials went so far as to describe sanctions as “the new FCPA” (referring to the US. Foreign Corrupt...more
2/17/2023
/ Civil Sanctions ,
Compliance ,
Economic Sanctions ,
Enforcement ,
EU ,
Liability ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Policies and Procedures ,
Russia ,
UK ,
Ukraine
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
Key Takeaways -
A judge has issued an opinion in a first-of-its-kind criminal sanctions case involving the use of virtual currency to evade U.S. economic sanctions. The opinion reinforces the Treasury Department’s position...more
At a New York City Bar Association event on April 27, Deputy Attorney General Lisa Monaco described economic sanctions as “the new FCPA.” Her characterization should put corporate compliance departments on notice. ...more
5/6/2022
/ Anti-Corruption ,
Compliance Management Systems ,
Corruption ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
FCPA Guidance ,
Foreign Corrupt Practices Act (FCPA) ,
Internal Controls ,
Military Conflict ,
Policies and Procedures ,
Russia ,
Ukraine ,
White Collar Crimes
Russia continues to introduce restrictive and other measures following the imposition of sanctions by the USA, EU, UK and other countries on Russia....more
3/14/2022
/ Counter Sanctions ,
Debt ,
Economic Sanctions ,
Financial Transactions ,
Foreign Corporations ,
Foreign Persons ,
Foreign Policy ,
Foreign Relations ,
Information Technology ,
International Trade ,
Russia ,
Ukraine
In response to the economic sanctions and export controls imposed on Russia by the US, EU, UK and other major economies, Russia imposed measures and countermeasures....more
Background As noted in our prior update, the United States, European Union and United Kingdom imposed a number of sanctions in connection with Russia’s recognition of the Donetsk and Luhansk regions of Ukraine. ...more
2/28/2022
/ Asset Freeze ,
Biden Administration ,
Economic Sanctions ,
EU ,
Export Controls ,
Financial Transactions ,
Foreign Policy ,
Foreign Relations ,
Foreign Trade Regulations ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
UK ,
Ukraine ,
Vladimir Putin
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
On February 15, 2022, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) published an initial set of regulations to implement sanctions targeting investments in Chinese Military-Industrial Complex...more
As concerns continue to build between Russia and the West over the situation in Ukraine, the United States, the European Union, and the United Kingdom are preparing measures that could be utilized if diplomacy is...more
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
In recent weeks, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) has issued guidance regarding both virtual currency and ransomware, demonstrating the agency’s enforcement priorities and compliance...more
On June 3, 2021, President Biden issued an Executive Order to modify sanctions initially imposed by former President Trump regarding investments in Chinese companies with alleged ties to the Chinese military. The new...more
Key Takeaways - Because digital currencies allow for high-value transactions outside of the traditional U.S. banking system, OFAC has rigorously investigated whether digital currency service businesses may be facilitating...more
In this OnPoint, we discuss new rules announced by China’s Ministry of Commerce (“MOFCOM”) aimed at counteracting the extraterritorial impact of foreign law on Chinese persons. ...more
On December 28, 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) released guidance on the implementation of sanctions targeting securities of Communist Chinese military companies (“CCMCs”) imposed...more
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
Background -
The U.S. Government, through the Treasury Department’s Office of Foreign Assets Control (“OFAC”), has imposed comprehensive sanctions against Syria since 2011. ...more
The outbreak of COVID-19 is impacting international trade as global markets deal with uncertain supply and companies and governments work to ensure personal safety while developing contingency plans for handling the virus. In...more
3/12/2020
/ Breach of Contract ,
Bureau of Industry and Security (BIS) ,
Coronavirus/COVID-19 ,
Economic Sanctions ,
Export Controls ,
Exports ,
Force Majeure Clause ,
General Licenses ,
Humanitarian Assistance ,
Infectious Diseases ,
Medical Supplies ,
Multinationals ,
Office of Foreign Assets Control (OFAC) ,
Risk Management ,
Sanction Violations ,
Supply Chain