The new EU notification requirements relating to transfers of funds out of the EU by EU entities with a certain level of direct or indirect Russian ownership enters into force soon. The reporting obligation has a broad scope,...more
UK Prime Minister Boris Johnson announces the “largest and most severe package of economic sanctions that Russia has ever seen” before Parliament and OFSI designates additional Russian entities and individuals as asset freeze...more
The UK Government has strengthened its Russian sanctions legislation by extending its sanctions designation criteria to target Russian businesses and individuals in a wide range of economic and strategically significant...more
The Court of Justice of the EU has interpreted for the first time the Blocking Regulation. The ruling confirms that it is possible to terminate contracts with a US designated person without providing reasons. However, in...more
The EU has extended until 31 January 2021 restrictive measures against Russia that target the financial, energy and defence sectors, as well as the area of dual-use goods....more
As of 16 March 2020 Iran Air and a number of other entities were placed on the Bureau of Industry and Security's (BIS) Entity List.
Summary -
Companies that use Iran Air as transport, particularly companies engaging in...more
3/17/2020
/ Airlines ,
Aviation Industry ,
Bureau of Industry and Security (BIS) ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Foreign Policy ,
General Licenses ,
Iran ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Prohibited Transactions
Earlier this month, France, Germany and the UK triggered the dispute process under the Iran nuclear deal, saying they had been "left with no choice" after Iran decided to further reduce compliance with the agreement. The...more
1/29/2020
/ Consultation Periods ,
Cooperative Compliance Regime ,
Dispute Resolution ,
EU ,
Failure to Comply ,
Foreign Policy ,
Foreign Relations ,
France ,
Germany ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Nuclear Weapons ,
The Joint Commission ,
Trump Administration ,
UK
On 14 October, President Donald Trump issued Executive Order 13894, Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation in Syria (EO).
...more
10/18/2019
/ Blocked Person ,
Economic Sanctions ,
Executive Orders ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Syria ,
Trump Administration ,
Turkey ,
Unauthorized Transactions
On 5 August 2019 the Trump administration issued Executive Order 13884 (the executive order) imposing sweeping sanctions against the government of Venezuela, including its agencies and instrumentalities as well as any...more
On 2 May 2019, the U.S. Treasury's Office of Foreign Assets Control ("OFAC"), the agency responsible for enforcing economic sanctions, published "A Framework for OFAC Compliance Commitments" (the "Framework") which outlines...more
7/3/2019
/ Cooperative Compliance Regime ,
Economic Sanctions ,
Failure to Comply ,
Foreign Policy ,
Foreign Relations ,
Framework Agreement ,
Fund Managers ,
Internal Controls ,
Investment Funds ,
Investment Management ,
Office of Foreign Assets Control (OFAC) ,
Private Equity ,
Risk Assessment ,
Sanction Violations