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EU and US Take Actions to Ease Belarus Sanctions

On October 29, 2015, the EU and the United States took separate action to ease certain Belarus-related sanctions. As of October 31, 2015, the EU suspended asset freezes and travel restrictions imposed on 170 persons, as well...more

OFAC Authorizes Certain Transactions and Activities to Liquidate Honduras-Based Bank

On October 21, following the October 7 designation of a Honduras-based bank as a Specially Designated Narcotics Trafficker, OFAC announced that it granted a General License authorizing certain transactions and activities to...more

Adoption Day in Iran Sanctions Deal: US and EU Give Clarification, But No Lifting of Sanctions Yet

The United States and European Union took preparatory steps on 18 October 2015 to begin fulfilling their commitments to suspend certain sanctions against Iran pursuant to the Joint Comprehensive Plan of Action (“JCPOA”)...more

Adoption Day Marks Start of Preparations for Iran Sanctions Relief

October 18, 2015 marked the starting point for official preparations for the expected lifting of sanctions against Iran under the recently agreed Joint Comprehensive Plan of Action (JCPOA). On this day, termed “Adoption Day,”...more

US State Department Releases Contingent Waivers of Iran Extraterritorial Sanctions

On October 18, 2015, the day on which the Joint Comprehensive Plan of Action (“JCPOA”) became effective (“Adoption Day”), the U.S. Department of State (“State Department”) issued contingent waivers of certain extraterritorial...more

“Adoption Day” Marks Official Launch of P5 + 1 Nuclear Deal with Iran

The Joint Comprehensive Plan of Action (JCPOA), intended to prevent Iran from acquiring a nuclear weapon and to ensure that Iran’s nuclear program will be directed toward exclusively peaceful purposes, went into effect...more

OFAC Announces Honduras-Based Bank as Specially Designated Narcotics Trafficker

On October 7, OFAC announced the designation of a Honduras-Based bank (the Bank) as a Specially Designated Narcotics Trafficker. According to the Department of the Treasury, this announcement “marks the first time that OFAC...more

OFAC and BIS Announce Further Easing of Cuba Sanctions

Effective September 21, 2015, the Department of Treasury’s Office of Foreign Assets Control (OFAC) and the Commerce Department’s Bureau of Industry and Security (BIS) have amended the Cuban Assets Control Regulations and...more

Colombian Companies Face New Compliance Challenges as Nation Ascends to World Economic Stage

When OFAC added Colombian sports franchise Envigado Fútbol Club to its sanctions list in June 2014, the news conjured up echoes of past dark days of “narco fútbol,” when the tentacles of organized crime touched the country’s...more

Iran Sanctions Relief: Opportunities and Challenges for US and EU Financial Institutions

Although US and EU sanctions targeting Iran are not likely to be lifted before early 2016, there are a number of issues which US and EU-based financial institutions should be aware of in preparation for sanctions relief as a...more

New OFAC Exposure? What Can Be Learned From Bank's Recent $1.7M OFAC Settlement for Investment-Related Transactions

Why it matters - Swiss-based UBS AG's agreement to pay more than $1.7 million to the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) underscores the scope of OFAC sanctions and the complications...more

FinCrimes Update - August 2015 Summary, Volume 2, Issue 8


Russia Sanctions Update

On September 2, 2015, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a final rule amending the Export Administration Regulations (EAR) by adding 29 parties to its Entity List, a...more

Leading International Financial Services Institution Pays $1.7 Million to Settle Sanctions Liability

On August 27, Treasury’s OFAC announced a settlement agreement requiring a Switzerland-based financial institution to pay slightly over $1.7 million to resolve potential liability over alleged violations of the Global...more

Is Iran Open for Business for U.S. Exporters?

On August 7, 2015, the U.S. Government issued a revised Guidance regarding Iran and also issued a Third Amended Statement of Licensing Policy on Activities Related to the Safety of Iran’s Civil Aviation Industry. The bottom...more

US Imposes Significant Export Restrictions on Russian Oil and Gas Field

The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) added the Yuzhno-Kirinskoye Field, a Russian oil and gas field, to the Entity List on August 7, 2015. The action effectively prohibits all persons from...more

Iran Sanctions: Change is Coming, But Risks and Uncertainties Remain

The Joint Comprehensive Plan of Action (“JCPOA”) that was signed on July 14, 2015 among Iran and the United States, Germany, UK, France, Russia and China (referred to as “P5+1” in the United States and “E3+3” in the EU) could...more

OFAC Provides Guidance to Financial Institutions to Help Comply with Crimea Sanctions Regulations

On July 30, OFAC issued a “Crimea Sanctions Advisory,” highlighting certain actions that have been used to circumvent or evade U.S. sanctions involving the Crimea region as described in Executive Order 13685. The Advisory...more

OFAC Releases Crimea Sanctions Advisory

On July 30, 2015, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a Crimea Sanctions Advisory highlighting certain practices that have been used to circumvent or evade U.S. sanctions...more

The Nuclear Deal With Iran: The Lifting of Sanctions and Implications for Business

On July 14, 2015, after two years of sometimes intense negotiations, the United States, the United Kingdom, France, Germany, Russia, and China (known as the “P5+1” countries), along with the European Union, signed a Joint...more

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

Additional U.S. Sanctions Imposed on Russian and Ukrainian Persons, But No Significant Escalation

On July 30, 2015, the U.S. Government added dozens of Russian and Ukrainian individuals and entities to the Ukraine-related sanctions lists.1 U.S. officials have stated that these new additions are not an escalation of U.S....more

U.S. Business Interests and the 2015 Iran Nuclear Settlement: A Critical First Appraisal

This has been a historic month for the United States and several other leading nations as they reached an apparent settlement with Iran over the development of its nuclear program. On July 14, the five permanent members of...more

Finalized Iran Nuclear Deal Outlines Changes for U.S. and EU Sanctions

On July 14, 2015, negotiators from Iran, the EU, and the P5+1 countries —China, France, Russia, the United Kingdom, the United States, and Germany—announced that they had reached a consensus on the final text of the Joint...more

Implications of the Iran Accord for the Maritime Industry

On July 14, 2015, the U.S., France, China, Russia, United Kingdom, Germany and the European Union (EU) entered into the Joint Comprehensive Plan of Action (JCPOA) with Iran after years of difficult negotiations. Iran agreed...more

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