The U.S. Commerce and Treasury Departments announced on January 26, 2016, actions to ease certain restrictions on transactions involving Cuba. The new actions do not significantly expand the types of activities in which U.S....more
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
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 ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Guilty Pleas ,
International Emergency Economic Powers Act (IEEPA) ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
PayPal ,
Sanctions ,
Schlumberger ,
Settlement ,
Sudan
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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 ,
Office of Foreign Assets Control (OFAC) ,
Sanctions ,
U.S. Treasury
Expansion into both new and emerging markets is a continuing trend for companies across many industry sectors. In a number of jurisdictions, local law restricts foreign companies from establishing wholly owned subsidiaries -...more
Has the Financial Conduct Authority (“FCA”) in the UK started as it means to go on? The FCA recently fined a UK subsidiary of a private Swiss Bank for failing to establish and maintain effective anti-money laundering controls...more