Tanya Hanna

Tanya Hanna

White & Case LLP

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US Issues Crimea Sanctions Advisory, Designates Additional Russian and Ukrainian Individuals and Entities

On July 30, 2015, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a Crimea Sanctions Advisory, identified certain subsidiaries of entities included on the Sectoral Sanctions Identifications...more

8/3/2015 - Banks Financial Services Industry OFAC Russia Sanctions SDN List SSI List Ukraine

Overview of Sanctions Relief in Nuclear Deal with Iran

On July 20, 2015, the United Nations Security Council (UNSC) unanimously adopted resolution 2231 endorsing the final nuclear deal agreed between the P5+1 (China, France, Russia, the United Kingdom, and the United States (US),...more

7/22/2015 - Aircraft Equipment Automotive Industry Energy Sector Financial Institutions Implementation Day Insurance Industry International Atomic Energy Agency Iran Iran Sanctions Joint Comprehensive Plan of Action (JCPOA) Metals Nuclear Power P5+1 Nations Shipping Transition Day UN Security Council United Nations

Final Nuclear Deal Reached Between Iran and the International Community

On July 14, 2015, the P5+1 (China, France, Russia, the United Kingdom and the United States (US), plus Germany), the European Union (EU), and Iran announced the “Joint Comprehensive Plan of Action” (JCPOA) regarding the...more

7/20/2015 - EU International Atomic Energy Agency Iran Iran Sanctions Joint Comprehensive Plan of Action (JCPOA) Nuclear Power Nuclear Weapons P5+1 Nations United Nations

Additional Extension of Temporary Sanctions Relief for Iran Through July 13, 2015

On June 30, 2015, the P5 + 1 (China, France, Germany, Russia, the United Kingdom, and the United States), the European Union (EU), and Iran decided by mutual consent to extend the Joint Plan of Action (JPOA) for seven days,...more

7/15/2015 - EU Extensions Iran Iran Sanctions JPOA P5+1 Nations Sanctions

Joint Plan of Action Temporary Sanctions Relief for Iran Continued Through July 7, 2015

On November 24, 2013, the P5+1 (China, France, Germany, Russia, the United Kingdom, and the United States, coordinated by the European Union's High Representative) and Iran reached an initial understanding, which was outlined...more

7/9/2015 - Iran Iran Sanctions JPOA Negotiations P5+1 Nations Time Extensions

Cuba No Longer Designated as a State Sponsor of Terrorism

On May 29, 2015, the United States formally rescinded Cuba's designation as a State Sponsor of Terrorism. This is another step in the improving relations between the United States and Cuba, potentially paving the path towards...more

6/4/2015 - Barack Obama Cuba Political Parties State Sponsors of Terrorism

Sanctions implications of the nuclear deal between Iran and the international community

Yesterday, an important tentative deal was agreed between the P5+1, the European Union, and Iran. Below, we look at what elements of the current sanctions could potentially be suspended or lifted if final agreement is reached...more

4/8/2015 - Iran Iran Sanctions JPOA Nuclear Power Nuclear Weapons

US Imposes Additional Ukraine/Russia- Related Sanctions By Designating Individuals and Entities Pursuant to Executive Orders 13660...

On March 11, 2015, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued further designations pursuant to Executive Order 13660 (EO 13660) and Executive Order 13685 (EO 13685). EO 13660, which was...more

3/13/2015 - Crimea Executive Orders OFAC Political Corruption Russia Sanctions Ukraine

US Issues Executive Order to Impose Venezuela Sanctions and Designates Seven Individuals

On March 9, 2015, President Obama signed an Executive Order entitled “Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation in Venezuela” (the “Order”). The authority for the Order includes...more

3/12/2015 - Executive Orders Sanctions Venezuela

US State Department Issues Section 515.582 List Regarding Authorization of Imports of Certain Goods and Services Produced by...

On February 13, 2015, the US Department of State published its “Section 515.582 List” and related guidance regarding the goods and services produced by independent Cuban entrepreneurs which have been authorized for immediate...more

2/19/2015 - Amended Regulation CACR Cuba Department of State Entrepreneurs Globally Harmonized System Imports OFAC Tariffs

After a busy 2014 for sanctions, what can we expect in 2015?

2014 was a very eventful year for sanctions, with both the European Union (EU) and United States (US) making extensive use of trade sanctions to attain foreign policy goals. Certain sanctions measures against Iran were (and...more

2/11/2015 - Crimea Cuba EU Iran Iran Sanctions Russia Sanctions SDN List SSI List Sudan Ukraine

Crimea-related Developments: OFAC Issues Authorizations for Certain Crimea-related Communications Activity and Personal...

On January 30, 2015, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued three General Licenses, authorizing certain personal remittances, the operation of personal accounts and certain mail and...more

2/5/2015 - BIS Crimea International Remittance Transfers OFAC Ukraine

US Implements Measures to Liberalize Cuba Sanctions and Export Controls

On January 16, 2015, the United States amended existing regulations to implement the changes announced by President Obama on December 17, 2014, liberalizing US sanctions and export controls targeting Cuba. As a result, the US...more

1/20/2015 - Amended Regulation Banking Sector BIS Cuba Embargo Executive Orders Export Controls Exports Imports Obama Administration OFAC Sanctions Telecommunications Trade Relations Travel Permits

US Issues Executive Order Imposing Sanctions with Respect to North Korea in Response to Recent Provocations

On January 2, 2015, President Obama signed an Executive Order (EO) authorizing the imposition of sanctions against the Government of North Korea and the Workers’ Party of Korea. Pursuant to this EO, the United States added...more

1/6/2015

US Authorizes Sanctions and Export Controls Against Venezuela

On December 18, 2014, President Obama signed into law the Venezuela Defense of Human Rights and Civil Society Act of 2014 (the “Act”). The legislation authorizes the United States to impose sanctions against certain...more

1/2/2015 - Defense Sector End-Users Export Controls Human Rights New Legislation Sanctions Venezuela

OFAC Issues General License Authorizing Certain Activities Necessary to Wind Down Operations Involving Crimea

On December 30, 2014, the US Department of the Treasury's Office of Foreign Assets Control (OFAC) issued General License 5, authorizing until February 1, 2015 certain activities otherwise prohibited by Executive Order 13685...more

1/2/2015 - Crimea Executive Orders OFAC Ukraine Winding Down

US Issues Executive Order Prohibiting Crimea-Related Transactions and General License No. 4 Authorizing Humanitarian Exports to...

On December 19, 2014, President Obama signed an Executive Order (EO) prohibiting a broad range of transactions related to the Crimea region of Ukraine and authorizing the United States to impose sanctions on certain persons...more

12/23/2014 - Barack Obama Crimea Executive Orders Exports OFAC Sanctions SDN List Ukraine

President Signs Russia Sanctions Law But Does Not Intend To Impose New Sanctions At This Time

On December 18, 2014, President Obama signed into law the Ukraine Freedom Support Act of 2014 (the “Act”), authorizing sanctions related to Russia’s defense, energy, and financial sectors. The Act is the latest in US...more

12/19/2014 - Banking Sector Barack Obama Defense Sector Energy Sector New Legislation Russia Sanctions Ukraine

US Announces Liberalization of Cuba Sanctions Policy

On December 17, 2014, President Obama announced the relaxation of certain aspects of the comprehensive trade embargo against Cuba that the United States has maintained since the early 1960s. As set forth by the White House,...more

12/18/2014 - Barack Obama Cuba Foreign Relations

Iran sanctions suspension extended, and other EU sanctions news (Syria, Belarus, Serbia/Montenegro)

This alert summarizes certain recent EU sanctions developments with respect to Iran, Syria, Belarus, and Serbia/Montenegro. In sum, they are as follows: • Iran: Today, the EU decided to extend the existing temporary...more

11/26/2014 - EU Extensions Iran Sanctions JPOA P5+1 Nations Sanctions

United States Tightens Sanctions Against Russian Financial, Defense, and Energy Sectors

On September 12, 2014, the United States issued another round of targeted sanctions against the Russian financial, defense, and energy sectors. Today’s measures were a combination of new measures and modifications of prior...more

9/15/2014 - Banking Sector Defense Sector Energy Sector Russia Sanctions SSI List

OFAC Issues Revised Guidance on Aggregation of Ownership Interests

On August 13, 2014, the US Treasury Department’s Office of Foreign Assets Control (OFAC) issued revised guidance with respect to the “50% Rule,” which established that an entity owned 50% or more, directly or indirectly, by a...more

8/15/2014 - Aggregation Rules Executive Orders OFAC Sanctions SDN List

US Expands Export Restrictions on Russia and Targets Russian Energy Sector

On August 1, 2014, the Bureau of Industry and Security (BIS) announced further export restrictions targeting Russia generally and the Russian oil and gas sector in particular, effective August 6, 2014. This action implements...more

8/8/2014 - BIS Energy Foreign Policy Russia Sanctions

United States Issues Further Sanctions Targeting Russian Financial, Defense and Energy Sectors

On July 29, 2014, the United States expanded sectoral sanctions, targeting the Russian financial, defense and energy sectors in response to the ongoing unrest in Ukraine. The new sanctions include the addition of three...more

7/31/2014 - Foreign Policy Russia Sanctions Ukraine

DC Circuit Requires Committee on Foreign Investment in the United States to Provide Due Process Protections to Investors

On July 15, 2014, the US Court of Appeals for the District of Columbia (DC Circuit) ruled that if the President, pursuant to his powers under the Exon-Florio Amendment to the Defense Production Act of 1950 (DPA), deprives a...more

7/25/2014 - Appeals Barack Obama CFIUS Divestiture Due Process Exon-Florio Foreign Nationals National Security Obama Administration Ralls Corporation Wind Farm

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