Key Takeaways - On 12 September 2024, the UK government published the Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024 (the “Regulations”), which will come into force on 10 October 2024. The...more
Key Takeaways - On 3 July 2024, the Council of the European Union (the “EU Council”) published its revised Update of the EU Best Practices for the effective implementation of restrictive measures (“Best Practices”).This...more
7/23/2024
/ Best Practices ,
Buyback Programs ,
Economic Sanctions ,
EU ,
Limited Liability Company (LLC) ,
Majority Shareholders ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Shell Corporations ,
Trusts ,
UK
EU’s 12th Sanctions Package - On 19 December 2023, the Council of the European Union (EU) together with the Commission published its 12th round of sanctions....more
12/27/2023
/ Asset Freeze ,
Banking Sector ,
Cryptocurrency ,
Economic Sanctions ,
EU ,
European Economic Area (EEA) ,
Export Controls ,
Fund Transfers ,
G7 ,
Imports ,
Information Sharing ,
Insurance Industry ,
Licensing Rights ,
Metals ,
Oil Prices ,
Pipelines ,
Propane ,
Reporting Requirements ,
Russia ,
SDN List ,
Software ,
Technology Sector ,
Telecommunications ,
Trade Restrictions ,
Transparency ,
UK
Key Takeaways -
On 17 November 2023, the Foreign, Commonwealth & Development Office (FCDO) and Office of Financial Sanctions Implementation (OFSI) published new guidance on Ownership and Control: Public Officials and...more
On 23 June 2023, the European Union (EU) adopted a new package of economic sanctions against Russia. In addition to other measures, the 11th sanctions package has specifically widened prior financial restrictions applicable...more
Introduction -
In 2022, the United States, European Union (EU) and United Kingdom, along with a significant number of other partners and allies, imposed an unprecedented number of economic, financial and trade sanctions...more
The United Kingdom just issued a new statutory instrument, effective immediately, which extends the authority to designate persons and entities under the U.K. sanctions against Russia.
Previously, the U.K. government...more
Key Points
- On December 14, 2020, in response to Turkey’s procurement of the S-400 surface-to-air missile system from Russia in 2019, the Trump administration imposed new sanctions on the Turkish Presidency of Defense...more
The new coronavirus, SARS-CoV-2, and the disease it causes, COVID-19, have created diverse, complex, and immediate challenges for world governments, multinational businesses, and other international institutions and projects....more
3/10/2020
/ Airports ,
Coronavirus/COVID-19 ,
Economic Sanctions ,
Exports ,
Federal Funding ,
Health and Safety ,
Imports ,
Infectious Diseases ,
Manufacturers ,
Medical Supplies ,
Multinationals ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
Public Health ,
Risk Assessment ,
Supply Chain ,
Trade Relations ,
Travel Restrictions ,
Travelers
• On June 5, 2019, the European Union (EU) took a step forward with respect to modernizing its existing dual use legislation under Council Regulation (EC) No 428/2009 (the “EU Dual Use Regulation”), with the European Council...more
6/12/2019
/ Dual Use Goods ,
Economic Sanctions ,
Emerging Technology Companies ,
EU ,
Export Controls ,
Exports ,
Human Rights ,
Information Security ,
Member State ,
Supply Chain ,
The Wassenaar Arrangement
• Yesterday, May 2, the United States government allowed implementation of Title III of the Helms-Burton Act, for the first time since the law was enacted in 1996, to permit U.S. nationals to sue persons that “traffic” in...more
5/3/2019
/ Banking Sector ,
Blocked Person ,
Cuba ,
Economic Sanctions ,
Financial Services Industry ,
Foreign Nationals ,
Foreign Relations ,
General Licenses ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Personal Jurisdiction ,
Risk Mitigation ,
Scope of Discovery Requests ,
Statute of Limitations ,
Trafficking ,
Travel Restrictions ,
Treble Damages ,
Trump Administration ,
U.S. Treasury ,
Visa Restrictions
• As of November 5, 2018, the United States concluded the second of two wind-down periods for re-imposition of U.S. sanctions on Iran following the May 8, 2018, announcement that the United States would cease participation in...more
11/27/2018
/ Aircraft ,
Blocking Statutes ,
Cross-Border Transactions ,
Economic Sanctions ,
EU ,
Exports ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Goods or Services ,
Humanitarian Assistance ,
Imports ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Nuclear Weapons ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Popular ,
SDN List ,
Special Purpose Vehicles ,
SWIFT ,
Trade Policy ,
Trump Administration ,
Vessels
• On August 6, 2018, following President Trump’s decision to withdraw the United States from the JCPOA, the U.S. government announced the reimposition of sanctions on Iran’s automotive sector, its trade in gold and precious...more
8/17/2018
/ Blocking Statutes ,
Economic Sanctions ,
EU ,
Executive Orders ,
International Relations ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Secondary Sanctions ,
Trade Relations ,
Trump Administration ,
Winding Down ,
Withdrawal
• The U.S. government has withdrawn from the Iran Nuclear Deal and reverted sanctions to the status quo ante by re-imposing secondary sanctions that restrict non-U.S. persons from engaging in a broad range of business in...more
5/10/2018
/ Controlled Foreign Corporations ,
Economic Sanctions ,
Exports ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Trade Policy ,
Trump Administration
• On May 1, 2018, OFAC issued General License 13A authorizing the divestment or transfer of certain debt, equity or other holdings issued by EN+ Group, GAZ Group or United Company RUSAL PLC, as well as entities in which such...more
Today, OFAC issued General License 14, authorizing U.S. persons to engage in specified transactions related to maintenance or wind down of operations, contracts or other agreements involving RUSAL until October 23, 2018,...more
• On April 6, 2018, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) placed seven prominent Russian businessmen, 12 companies, 17 senior Russian government officials, and a state-owned Russian...more
4/9/2018
/ Banking Sector ,
Blocked Person ,
CAATSA ,
Economic Sanctions ,
Executive Orders ,
Financial Institutions ,
General Licenses ,
Government Officials ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
State-Owned Enterprises ,
Trump Administration ,
U.S. Treasury
• Effective October 13, 2017, President Trump declined to provide certification that the JCPOA is in the United States’ national interest. Following this “decertification,” the U.S. Congress has 60 days in which to introduce...more
11/2/2017
/ Anti-Terrorism Financing ,
Decertify ,
Economic Sanctions ,
Executive Orders ,
Foreign Policy ,
Foreign Relations ,
Iran ,
Iran Nuclear Agreement Review Act of 2015 (INARA) ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Legislative Amendments ,
Members of Congress ,
Nuclear Weapons ,
Office of Foreign Assets Control (OFAC) ,
Proposed Legislation ,
SDN List ,
Sunset Provisions ,
Trump Administration ,
U.S. Treasury
• On October 27, 2017, the U.S. State Department issued guidance identifying 39 entities related to the defense and intelligence sectors of the Government of the Russian Federation and issued related guidance on criteria to...more
10/31/2017
/ Defense Sector ,
Economic Sanctions ,
Export-Import Bank of the US ,
Exports ,
Extraterritoriality Rules ,
Financial Institutions ,
Foreign Exchanges ,
National Intelligence Agencies ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Secretary of the Treasury ,
State-Owned Enterprises ,
Trump Administration ,
US State Departments
Based on certain State Department findings, effective October 12, 2017, long-standing U.S. sanctions on the Republic of Sudan administered by OFAC under the Sudan Sanctions Regulations will be terminated, and U.S. persons...more
10/13/2017
/ Bureau of Industry and Security (BIS) ,
Commerce Control List ,
Commodities ,
Department of Defense (DOD) ,
Economic Sanctions ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Exports ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Secretary of State ,
Sudan ,
Trade Restrictions ,
Trump Administration ,
TSRA
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
8/21/2017
/ Annexation ,
Asset Freeze ,
Crimea ,
Economic Sanctions ,
Energy Sector ,
EU ,
Export Controls ,
Oil & Gas ,
Power Plants ,
Russia ,
Siemens ,
Trade Restrictions ,
Travel Ban ,
Ukraine