Miriam Gonzalez

Miriam Gonzalez

Dechert LLP

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Latest Publications


U.S. Government Takes Steps to Further Ease Restrictions on Cuba

U.S. Commerce and Treasury Department measures intended to further ease existing export and sanctions restrictions regarding Cuba took effect on September 21, 2015. These amendments to the Cuban Assets Control Regulations...more

9/28/2015 - Cuba Cuban Assets Control Regulations (CACR) Export Administration Regulations Export Controls Internet Telecommunications Trade Restrictions U.S. Commerce Department U.S. Treasury

Iran Deal “Clears” Congress, But No Sanctions Relief Yet

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

EU-Vietnam Trade Deal

The EU and Vietnam have concluded the substantive elements of a Free Trade Agreement (FTA), widely-hailed as one of the most ambitious and comprehensive such agreements that the EU has concluded with a developing country....more

8/28/2015 - ASEAN Funds Customs Duties EU Exports Free Trade Agreement Imports Origin Public Contracts Tariffs Vietnam

EU sanctions on Iran: Technical Amendments

The European Council has adopted two technical amendments to the EU’s sanctions on Iran. While related to the implementation of the Joint Comprehensive Plan of Action (JCPOA) agreed with Iran on 14 July, their effect is...more

8/6/2015 - EU Implementation Day International Atomic Energy Agency Iran Iran Sanctions Joint Comprehensive Plan of Action (JCPOA) Nuclear Power Nuclear Weapons UN Security Council

The UK Modern Slavery Act 2015 (“the Act”) enters into force today. If you are a supplier of goods or services with a turnover of...

Annual Statements - The Act requires commercial organisations to publish an annual slavery and human trafficking statement. This must set out the steps that the organisation has taken in that financial year to ensure...more

8/5/2015 - Human Trafficking Modern Slavery Act Reporting Requirements Sale of Goods Suppliers UK

UK Export Licensing Trends

The Export Control Organisation (ECO) has released its latest set of data on export licensing. For the first time, this has been produced to be compliant with the UK Statistics Authority’s code of practice for official...more

7/24/2015 - Export Controls Exports Licensing Rules Military Goods UK

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

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

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

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

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

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