Sanctions

News & Analysis as of

Changes to Sudanese Sanctions Program Could Benefit U.S. Life Sciences Companies (A Little)

On January 13, 2017, President Obama signed the Executive Order “Recognizing Positive Actions by the Government of Sudan and Providing for the Revocation of Certain Sudan-Related Sanctions” that revoked many U.S. economic...more

OFAC Authorizes Certain Dealings with Russian Security Agency

In its first public statement since the inauguration, the US Department of Treasury’s Office of Foreign Assets Control (OFAC) announced on February 2, 2017, that it had authorized limited dealings with the Federal Security...more

Sanctions and the Terrible, Horrible, No Good, Very Bad Appeal

This may not be a book my new grandson Felix will soon be reading, but it does raise a legitimate question: When you really, truly, believe a federal appeal is frivolous, and not just garden variety, I know you’re going to...more

ESI Discovery Best Practices, Part 7 – New FRCP One Year In – ESI Game Changer or Business As Usual?

I was recently reminded that it has been over a year since my last ESI-related blog. My excuse is that I wanted to allow the new Federal Rules of Civil Procedure addressing ESI to percolate before writing on the...more

Bridging the Week - February 2017

Making Regulation Great Again: President Trump Requires Loss of Two Regulations for Every New One and Orders Review of All Financial Services Laws and Rules: Last week, through the issuance of two executive orders, President...more

Exploring the Rule 3002.1 Minefield

In September 2016, the U.S. Bankruptcy Court for the District of Vermont ordered a mortgage servicer to pay a $375,000 sanction to a nonprofit legal aid organization for failing to comply with Rule 3002.1 of the Federal Rules...more

Lack Of Prejudice Results In Limited Sanction Against Defendant

In one of the first cases interpreting newly amended Fed. R. Civ. P. 37, F.T.C. v. DirecTV, Inc., 15-cv-01129-HSG, 2016 U.S. Dist. LEXIS 176873 (N.D. Cal. Dec. 21, 2016), Magistrate Judge Maria Elena James of the Northern...more

Ninth Circuit Accords Chevron Deference To The SEC, What Would Judge Gorsuch Say?

Last week, I noted that Judge Gorsuch has expressed a certain skepticism of Chevron deference. The next day, the Ninth Circuit Court of Appeals held that the Securities and Exchange Commission’s interpretation of Section...more

U.S. Designates New Individuals and Entities for Iran-Related Sanctions

Today, the U.S. Treasury Department, Office of Foreign Assets Control (“OFAC”) imposed sanctions on an additional 13 individuals and 12 entities identified by the Treasury Department as “entities and individuals involved in...more

General License for Commercial Authorizations from Sanctioned Russian Security Agency

OFAC has issued a new General License to address problems raised by the sanctioning of the Federal Security Services (FSB). This adjustment serves to authorize permits by the FSB needed for certain commercial transactions...more

The Sanctions Committees of the French Financial Regulators: Overview of the Activity in 2016

In 2016, the French financial regulators, the ACPR and the AMF, continued to pay particular attention to infringements in matters of anti-money laundering and anti-terrorism, internal control procedures, conflicts of interest...more

Leaving on a Reconciliatory Note: President Obama Ends His Term with a Substantial Easing of the Sudanese Sanctions Regime

The U.S. Department of the Treasury (Treasury) recently announced a significant relaxation of the U.S. sanctions with respect to Sudan that are currently administered by the Office of Foreign Assets Control (OFAC). The...more

New monetary penalty regime for breach of financial sanctions

There will soon be a new regime in place in the UK for punishing individuals or businesses that breach financial sanctions. In March 2016 the Office of Financial Sanctions Implementation (OFSI) was formed, as part of the...more

Are All Troll Cases Exceptional?

In Iris Connex, LLC, v. Dell, Inc., [2:15-cv-1915-JRG] (January 25, 2016), District Judge Gilstrap, after granting summary judgment to Dell, awarded attorneys fees, noting Dell’s arguments that Iris Connex’s claim...more

Failure to Disclose Not Justified by Non-Fifth Circuit Authorities

Lisa Velasquez Olivarez claimed that a GEO employee sexually assaulted her while she was incarcerated in the Maverick County Detention Center. She made recorded phone calls from prison to her mother and a friend, suggesting...more

Will the Proposed “Countering Russian Hostilities Act” Stop Russian Cyberattacks?

On Jan. 10, 2017, a bipartisan group of five Republican and five Democratic senators announced their support for the Countering Russian Hostilities Act of 2017. Lindsey Graham, one of the senators who announced the proposed...more

Top 12 EU Legal Developments to Watch in 2017

Sheppard Mullin’s EU team has created a list of major legal shifts that await General Counsel and Compliance Officers in the areas of competition, EU regulatory and trade in 2017. These challenges may have an impact on your...more

Amid Wave of Final Executive Actions, President Obama Eases Sanctions Against Sudan

On January 13, 2017, the White House issued an executive order revoking significant aspects of the sanctions in place against Sudan (that have been in effect since 1997). In conjunction with the announcement, the Treasury...more

Recent OFAC Amendments - Sudan & Iran

Recent OFAC Amendments Make Significant Changes to Sudanese Sanctions Regulations, Expand General Licenses for Agricultural Commodities, Medicine and Medical Devices under the Iran Transactions and Sanctions Regulations, and...more

Obama Administration Announces Relief of Sudan Sanctions Measures

On January 13, 2017, President Barack Obama signed an Executive Order (the “Sudan Executive Order”) that will effectively revoke, after six months (i.e., on July 12, 2017), the U.S. trade embargo against Sudan, provided the...more

OFAC Issues General License Authorizing Most Transactions with Sudan

On January 13, 2017, President Obama signed Executive Order 13761 (“E.O. 13761”), “Recognizing Positive Actions by the Government of Sudan and Providing for the Revocation of Certain Sudan-Related Sanctions.” Effective July...more

Donald Trump and Shipping: What to Expect

The election of Donald J. Trump as President of the United States took many by surprise. Of additional import to the industry, the Republican Party has maintained control of the House of Representatives and the Senate,...more

U.S. Issues General License Authorizing Trade and Financial Dealings with Sudan

On Jan. 13, 2017, President Barack Obama signed Executive Order 13761 (the Executive Order) authorizing the lifting of portions of the United States’ trade and financial sanctions on Sudan. The action is the result of...more

OFAC Issues New General License to Significantly Lift Sudan Sanctions

On January 13, 2017, President Obama made sweeping changes to the Sudan sanctions program, removing the majority of the sanctions in place against this war-torn nation. The final decision will be in the hands of...more

Obama Administration Eases Sanctions on Sudan

On January 13, 2017, the Treasury Department, citing an executive order issued by President Obama on the same day, announced the issuance of a general license, effectively lifting most sanctions against Sudan. The general...more

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