On June 12, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced new measures targeting Russia’s financial infrastructure, including:
1. Expanding the scope of financial sanctions:...more
The EU is going extraterritorial, and it is doing so through private contract. It is a pretty neat trick.
As a general rule, EU regulations do not apply extraterritorially. This policy is a bit pointed, intended to stand...more
3/28/2024
/ Asset Freeze ,
Buyers ,
EU ,
European Commission ,
Exporters ,
Exports ,
Extraterritoriality Rules ,
Importers ,
Imports ,
Member State ,
Russia ,
Sanctions ,
SDN List ,
Ukraine
Grants and tax credits, who doesn’t love them? The Bipartisan Infrastructure Law (BIL) is full of them, and, recent Department of Energy (DOE) Notification of a Proposed Interpretive Rule provides guidance on who will get to...more
1/15/2024
/ Automated Transportation ,
Batteries ,
Clean Energy ,
Department of Energy (DOE) ,
Electric Vehicles ,
Energy Sector ,
Foreign Entities ,
Manufacturers ,
Office of Foreign Assets Control (OFAC) ,
Proposed Rules ,
Renewable Energy ,
SDN List ,
Supply Chain
On June 23, 2023, the EU released its 11th package of sanctions on Russia. This package is designed to improve enforcement with new anti-circumvention rules, new trade restrictions, and new designations. The...more
6/26/2023
/ Asset Freeze ,
Crude Oil ,
Economic Sanctions ,
EU ,
Export Controls ,
Imports ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Russia ,
SDN List ,
Supply Chain ,
UK ,
Ukraine
In response to Russia’s ongoing aggression in Ukraine, both the United States and the European Union have imposed additional sanctions and further restricted exports to Russia and Iran. These new controls span many...more
2/28/2023
/ Economic Sanctions ,
Entity List ,
EU ,
Export Controls ,
Exports ,
Iran ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Trade Restrictions ,
UK ,
Ukraine
On May 6, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated a cryptocurrency mixer, Blender.io, as a Specially Designated National (SDN). That sanction follows a series of enforcements and...more
Updated as of April 12, 2022 -
It has now been more than 40 days since the start of Putin’s brutal invasion of Ukraine. Today, following the recent revelations of the atrocities committed in Bucha, Ukraine by Russian armed...more
4/13/2022
/ Asset Freeze ,
Belarus Sanctions ,
Economic Sanctions ,
EU ,
Export Controls ,
Financial Transactions ,
G7 ,
General Licenses ,
Investment ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Trading Restrictions ,
UK ,
Ukraine
It has now been more than 40 days since the start of Putin’s brutal invasion of Ukraine. Today, following the recent revelations of the atrocities committed in Bucha, Ukraine by Russian armed forces, the United States – in...more
Updated as of February 25, 2022 -
Key Takeaways of OFAC (Treasury) and BIS (Commerce) Actions -
Major Russian Banks Blocked from the U.S. Financial System. Six major Russian banks — VEB, Promsvyazbank (PSB), VTB Bank,...more
On May 8, 2018, the United States withdrew from the Joint Comprehensive Plan of Action and reimposed all pre-JCPOA sanctions against Iran... After a prescribed wind-down period, all U.S. sanctions on Iran are now in force....more
11/6/2018
/ Economic Sanctions ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
Foreign Relations ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Trump Administration ,
Waivers
I spent last week in Seoul talking to clients about the latest changes to U.S. trade and sanctions policy (as South Korea is one of Iran’s largest trading partners, it is understandable that some concerns have arisen there in...more
6/8/2018
/ Business Opportunities ,
China ,
Cross-Border Transactions ,
Economic Sanctions ,
Foreign Investment ,
Foreign Relations ,
Infrastructure ,
North Korea ,
SDN List ,
South Korea ,
Trade Policy ,
Trump Administration
1. All sanctions on Iran that were in place before January 2016 will be re-imposed no later than November, 4 2018.
2. Secondary sanctions that penalize non-U.S. persons doing business with Iran will be reinstated.
3....more
5/14/2018
/ Economic Sanctions ,
Exports ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Goods or Services ,
Imports ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
NDAA ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Trump Administration
What does decertification mean?
For the time being, decertification is a solely U.S. issue. Under the Iran nuclear agreement (known as the Joint Comprehensive Plan of Action, or JCPOA), Iran agreed to limits on its nuclear...more
10/13/2017
/ Automotive Industry ,
Banking Sector ,
Energy Sector ,
Financial Transactions ,
Foreign Subsidiaries ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Nuclear Weapons ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Shipping ,
Sovereign Debt
- A President Trump will have authority to reinstate sanctions lifted by the Iran Nuclear Deal as well as revoke certain authorizations provided for business with Iran.
- Several economic and geopolitical factors may...more
12/8/2016
/ Business Opportunities ,
Corporate Counsel ,
Executive Orders ,
Global Market ,
International Relations ,
International Treaties ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Nuclear Weapons ,
Office of Foreign Assets Control (OFAC) ,
Presidential Elections ,
SDN List ,
Trump Administration
Article Highlights:
- Non-U.S. banks can do business with Iran and continue their relationships with U.S. banks.
- Non-U.S. companies may use proceeds from Iran transactions more freely, including in the United...more
On June 20, 2016, you will be able to take a non-stop flight from Tehran to Paris . . . but you probably shouldn’t.
According to its website, the Iranian airline Mahan Air will add the City of Lights to the list of...more
After weeks of negotiations and a Putin-backed delay, the UN Security Council unanimously adopted resolution 2270 on March 2, 2016, imposing new sanctions against North Korea. According to U.S. Secretary of State John Kerry,...more
3/4/2016
/ Arms Embargo ,
Asset Freeze ,
Corporate Counsel ,
Exports ,
Imports ,
North Korea ,
Nuclear Weapons ,
Office of Foreign Assets Control (OFAC) ,
Sanctions ,
SDN List ,
UN Security Council ,
Vessels ,
WMD
On 16 January 2016, the United States and the EU lifted certain sanctions against Iran in compliance with the Joint Comprehensive Plan of Action (JCPOA) agreed among Iran, China, France, Germany, the Russian Federation, the...more