Sanctions

News & Analysis as of

Freedom to Retaliate against Foreign Whistleblowers May Not Be as Much Fun as It First Appears

What I’m about to say is grossly oversimplified, but here goes: The Dodd-Frank Act’s whistleblower provisions have two primary prongs. The first says that an individual who voluntarily provides the SEC with original...more

New York Announces Latest Action Against A Bank Consulting Firm

On August 18, the New York DFS announced an agreement with a bank consulting firm to resolve allegations related to certain services it performed for a bank charged last year with sanctions violations. The consulting firm...more

FIFA rejects FC Barcelona appeal against transfer ban

On April 2014 the FIFA Disciplinary Committee sanctioned FC Barcelona for reported breaches about the signing of under-age players with a year-long transfer ban and significant fines....more

Russia Sanctions: Impact on Financial Institutions in the US, EU and Japan

New sanctions targeting Russia have been implemented in the US, EU and Japan. Although the consequences of breaching the sanctions are severe, navigating the rules is not straightforward. Transactions and business lines will...more

EU Sanctions Against Russia: Possible Effects on Aircraft Sector

Against the background of recent European Union (EU) sanctions targeting Russian airline Dobrolet, this note provides a general overview of relevant issues – especially in the context of the aircraft sector. I....more

Tit-for-Tat: Russia's Ban on Food Imports May Mean Leaner Times for Some U.S. and EU Exporters

Following a steady stream of sanctions by the U.S. and EU, Russia finally retaliated by imposing a ban on food imports. The one-year ban instituted on August 7, 2014, prohibits the importation into Russia of meat, fish,...more

SEC Announces Additional Settlement Under Municipal Continuing Disclosure Cooperation Initiative

The SEC recently announced another issuer settlement under its Continuing Disclosure Cooperation Initiative (see our blogs First Settled Proceeding (July 23, 2014). In this settled action, Kansas consented to the standard...more

OFAC Issues Revised Guidance on Entities Owned by Persons Whose Property and Interests in Property are Blocked

The Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has issued revised guidance with respect to entities owned 50 percent or more in the aggregate by one or more blocked persons....more

OFAC Issues New Guidance Regarding Status of Entities Owned by Specially Designated Nationals and Blocked Persons

The U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued new guidance regarding the status of entities that are 50% or more owned by persons or entities whose property and interests in property are...more

New EU Sanctions Target Russian Oil Sector, State-Owned Banks and Military Exports

The European Union (EU) enacted Council Regulation (EU) No 833/2014 (the Regulation), which contains ‘Stage 3’ sanctions against Russia. These sanctions resemble – but in other ways are different – from the latest US...more

New OFAC Guidance on 50% Rule Expands Reach of US Sanctions

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

Tort Actions Against Public Entities – CCP § 1038 Sanctions Cannot be Awarded Against Parties’ Counsel

Kathryn Settle v. State of California - California Court Of Appeal, Second Appellate District (July 23, 2014) - When a public entity is sued in tort, Code of Civil Procedure (“CCP”) § 1038 requires a mandatory...more

New Sanctions Guidance Increases Due Diligence Burden on Companies

On August 13, 2014, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) published guidance (“Revised Guidance”) that revises its 2008 guidance regarding how to treat entities that are owned or...more

"US Imposes New Licensing Requirements on Exports to Russia of Oil and Gas Equipment and ‘Dual-Use’ Items"

On August 6, 2014, in response to continuing developments in Ukraine, the U.S. Commerce Department’s Bureau of Industry and Security (BIS) published a new final rule that significantly expands restrictions on U.S. exports to...more

Exaggeration of Counsel’s Class Action Experience Draws Rule 11 Sanction

New York District Court Judge Shira A. Scheindlin found class counsel’s allegation that they were experienced and competent was false because they could not provide any case in which they were certified as class counsel or...more

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

The US sanctions against Russia – in an evolving context, key points for business

Starting in March of this year, the United States imposed economic sanctions in response to Russian-led actions in Ukraine. Since March, responding to the deteriorating situation, US sanctions have continued to escalate. ...more

Department of Commerce and OFAC Continue Imposing Hefty Sanctions on Russia, While Russia Retaliates with Own Sanctions

On August 6, the U.S. Department of Commerce (the “Commerce Department”) issued new regulations, implementing additional sanctions against Russia and introducing new restrictions on exports for its energy sector. These new...more

Update on EU sanctions on Ukraine and Russia pertinent to Cyprus, BVI and Cayman

New EU restrictions and prohibitions - As the crisis over Ukrainian sovereignty has deepened, notably following the crash of Malaysia Airlines Flight 17, the EU has sought to increase punitive measures on rebel groups...more

Further European Union Sanctions Target Russia, Whilst Russia Retaliates

The United States, European Union and Canada each took steps recently to expand sanctions against Russia, including the targeting of major defense companies and the addition of export controls. These designations and export...more

The 21st Century Water Cooler: Discovery and Text Messages

Text messages, once the exclusive domain of teenagers and college students, are increasingly used in business communications. These communications are, unsurprisingly, also discoverable in a wide variety of litigation...more

The new EU sanctions against Russia – key points to know, key steps for companies with business interests in Russia

The European Union has adopted economic sanctions against Russia – the latest step relating to the protection of the territorial integrity of Ukraine. Earlier this year, the Council of the European Union had already adopted...more

Russia imposes sanctions against the United States, the European Union, Australia, Canada and Norway

On 6 August Vladimir Putin, the President of Russia, signed a decree calling for a ban or limit on imports of certain agricultural products, raw materials and foodstuffs originating in the countries that have imposed economic...more

Russia Bans the Import of Certain Agricultural and Food Products from the US, EU, Canada, Australia, and Norway

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

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

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