Medical device companies have a new regulatory pathway for exporting certain U.S.-origin medical products to Russia, Belarus, Crimea and other regions of Ukraine (i.e., the so-called Donetsk People’s Republic and Luhansk...more
On December 13, 2023, CoinList Markets LLC (“CoinList”) agreed to pay $1,207,830 pursuant to a settlement agreement with the Office of Foreign Assets Controls (“OFAC”) in connection with allegations that the San Francisco...more
On December 13, 2023, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) announced an enforcement action against CoinList Markets LLC (“CoinList”) for violations of the Ukraine-/Russia-Related...more
The Office of Foreign Asset Control (“OFAC”) announced on June 20 that Swedbank Latvia AS (“Swedbank Latvia”), a subsidiary of Swedbank AB (“Swedbank AB”) headquartered in Riga, Latvia, agreed to pay $3,430,900 to settle its...more
OFAC continues its enforcement push. At the same time, OFAC is managing a complex, global set of sanctions against Russia. DOJ has promised to increase prosecution of global banks for sanctions violations....more
In this post, we describe the territorial sanctions imposed by Canada in relation to Ukrainian territory that has been annexed by Russia as well as other sanctions on Russian persons and on certain Ukrainians who have...more
Under a statutory instrument promulgated under the Sanctions and Anti-Money Laundering Act 2018 (amending the Russia (Sanctions) (EU Exit) Regulations 2019)), the UK government recently passed sweeping new trade restrictions...more
Prosecutors and regulators are scouring their files for enforcement actions – criminal and civil – for violations of the 2014 Ukraine-Russia Sanctions Program. The message being sent is clear – do not violate any sanctions...more
The U.S. Attorney’s Office for the Southern Direct of New York recently announced the indictment of Jack Hanick, a United States citizen, of violating the U.S. sanctions against Russia and false statements in connection with...more
Our International Trade & Regulatory Group addresses the new U.S. sanctions against Russia announced this week in response to its actions against Ukraine and summarizes the similar packages announced by key U.S. allies....more
On February 21, 2022, President Biden issued an Executive Order (EO) to impose a first round of sanctions in response to Russian President Putin’s actions with respect to the Donetsk People’s Republic (DNR) and Luhansk...more
On April 15, 2021, President Biden issued Executive Order 14024 (the EO), imposing new sanctions on the Russian Federation in response to foreign election interference in the 2020 U.S. federal election and the SolarWinds...more
While the Biden Administration desires a “stable and predictable” relationship with Russia, it has now made it clear that it will take “actions to impose costs on Russia for actions by its government and intelligence services...more
President Biden issued a new Executive Order 14024 (“E.O. 14024”) on April 15, 2021, expanding sanctions against Russia. E.O. 14024 authorizes, for the first time, U.S. sanctions against Russian technology companies and,...more
On 15 April 2021, the U.S. Government announced a number of new sanctions measures against Russia, targeting a variety of “harmful foreign activities” contrary to U.S. foreign policy. ...more
The Biden Administration announced new and significant trade sanctions against Russia. The action was long expected given the Biden Administration’s criticism of Russia, and was a comprehensive response to Russia’s...more
On April 15, 2021, the Biden Administration imposed new sanctions on Russia in response to: (1) its efforts to interfere in U.S. and other countries’ elections; (2) the Solar Winds hacks; and (3) Russia’s continued occupation...more
The still evolving US sanctions (as well as the EU and now also separate UK sanctions) continue to challenge Russia-related business. The sanctions frameworks are complex, changing, and, at times, inconsistent as well as...more
The Treasury Department’s Office of Foreign Asset Control continues to focus enforcement activities on digital currency companies. This focus is likely to increase given recent comments by Janet Yellen, the head of the...more
United States - Various threats of further broad sanctions… triggered by ongoing negative developments and perceptions in the US-Russia relationship – though new sanctions legislation seems unlikely before the 3 Nov. US...more
This presentation, an update to our April 2020 presentation, highlights the most recent developments and then provides a detailed overview of the relevant frameworks and their possible implications—including a focus on the...more
Amazon joins the exclusive club of high-tech OFAC violators. Last year, Apple settled with OFAC for sanctions violations. This year, we can add Amazon to the list of OFAC violators. ...more
In an increasingly integrated global economy, and as businesses shift to online sales and a broader client base, it is important to have a clear understanding of, among other things, the U.S. sanctions in place, and the...more
Russia-Related Sanctions Codification: The new law codifies sanctions executive orders related to circumstances in Ukraine and Crimea as well as certain cyber-enabled activities, restricting the U.S. President's authority to...more
On August 4, 2017, the Council of the European Union (the “Council”) made six new designations to the list of persons subject to restrictive measures in respect of actions undermining or threatening the territorial integrity,...more