This quarter, the U.S. announced new sanctions and trade restrictions on China in response to its perceived intrusions on Hong Kong’s autonomy and reported human rights abuses in Xinjiang. The Trump Administration acted...more
This quarter, the U.S. acted pursuant to statute to punish Russia for its alleged role in the chemical weapons attack on Sergei Skipal and targeted a handful of individuals and entities for certain other malign activities....more
10/21/2019
/ AML/CFT ,
Anti-Corruption ,
CAATSA ,
Criminal Conspiracy ,
Economic Sanctions ,
Enforcement Actions ,
Executive Orders ,
Export Controls ,
Exports ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Trump Administration
SECOND QUARTER 2019 –
- US extends sanctions to encompass Iranian metals industries and other targets; Iran announces breach of nuclear accord after EU is unable to offset economic impact of renewed US sanctions.
-...more
In this quarter, OFAC lifted sanctions on Rusal and other companies following divestment by Oleg Deripaska. Meanwhile, as Venezuela descends into economic and political crisis, the US targeted PdVSA and others to hasten...more
5/10/2019
/ Counter-Terrorist ,
Cuba ,
Economic Sanctions ,
Enforcement Actions ,
Foreign Policy ,
Helms-Burton Act ,
Iran ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Trade Relations ,
Trump Administration ,
Venezuela
Closing out 2018, OFAC announced its plan to lift sanctions against United Co. Rusal and others, despite bi-partisan opposition from Congress. Simultaneously, OFAC continued to target Russia’s defense and intelligence sectors...more
1/23/2019
/ Counter-Terrorist ,
Drug Trafficking ,
Economic Sanctions ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
General Licenses ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Magnitsky Act ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Trafficking ,
Trump Administration ,
Venezuela
Russia remained at the forefront this quarter, as the Trump Administration imposed new measures and markets reacted to the threat of additional, “crushing” sanctions from Congress on Russian sovereign debt. Meanwhile, EU...more
10/17/2018
/ CAATSA ,
Chemical Weapons ,
Counter-Terrorist ,
Economic Sanctions ,
Enforcement Actions ,
EU ,
Executive Orders ,
Financial Institutions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Magnitsky Act ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Russia ,
Sovereign Debt ,
Trump Administration ,
UK ,
Venezuela
This quarter, companies around the globe prepared to exit Iran-related business in the wake of U.S. sanctions snap-back. Meanwhile, OFAC provided a path to relief to designated Russian entities, extending several deadlines...more
7/12/2018
/ Counter-Terrorist ,
Drug Trafficking ,
Economic Sanctions ,
Enforcement Actions ,
Foreign Policy ,
General Licenses ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Magnitsky Act ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
South Korea ,
Trump Administration ,
Ukraine ,
Venezuela
President Trump announced today the United States’ withdrawal from the Joint Comprehensive Plan of Action and initiated plans to re-impose nuclear-related sanctions that had been suspended under the terms of the 2015 nuclear...more
This quarter saw the announcement of sweeping new sanctions against Russia’s billionaire class and their corporate holdings, and included the Trump Administration’s first issuance of sanctions against Russia for meddling in...more
4/16/2018
/ CAATSA ,
Counter-Terrorist ,
Criminal Prosecution ,
Drug Trafficking ,
Economic Sanctions ,
General Licenses ,
Iran Sanctions ,
Narcotics ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanction Violations ,
SDN List ,
SSI List ,
Terrorism Funding ,
Trump Administration ,
Ukraine ,
Venezuela
Headlines from the final months of 2017 included the signing of a new executive order with global anti-corruption implications; new guidance on the Trump Administration’s approach to Russia sanctions under CAATSA; tightening...more
1/9/2018
/ Counter-Terrorist ,
Cuba ,
Drug Trafficking ,
Economic Sanctions ,
Executive Orders ,
Iran Sanctions ,
Magnitsky Act ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sudan ,
Trump Administration
The third quarter was headlined by the imposition of broad new US legislative sanctions against Russia, Iran, and North Korea. The Trump Administration also acted unilaterally to significantly expand sanctions against both...more
Shearman & Sterling’s bi-annual Trends & Patterns in FCPA Enforcement report provides insightful analysis of recent enforcement trends and patterns in the US, the UK and elsewhere, as well as helpful guidance on emerging best...more
7/6/2017
/ Chief Compliance Officers ,
Compliance ,
Corporate Counsel ,
Deferred Prosecution Agreements ,
Disgorgement ,
Enforcement Actions ,
Enforcement Statistics ,
Foreign Corrupt Practices Act (FCPA) ,
Jurisdiction ,
Litigation Privilege ,
Securities and Exchange Commission (SEC) ,
Settlement ,
Statute of Limitations ,
Trump Administration ,
UK
The first six months of the Trump Administration saw several notable developments for US sanctions, with particular implications for Russia and Iran. The Administration also declared a shift in US policy toward Cuba. ...more
7/6/2017
/ Counter-Terrorist ,
Cuba ,
Drug Trafficking ,
Economic Sanctions ,
Enforcement Actions ,
Exxon Mobil ,
Foreign Policy ,
Iran Sanctions ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Proposed Legislation ,
Russia ,
Trump Administration ,
Ukraine
On June 16, 2017 during a speech in Miami, President Trump announced changes to US sanctions targeting Cuba. The speech announced two substantial changes to the previous administration’s Cuban sanctions regime: first, the new...more
On November 8, 2016, Donald John Trump was elected the 45th President of the United States. Following fiery criticism of the Obama Administration’s sanctions policies, including the Iran deal, the lifting of substantial parts...more
On January 4, 2017, President-elect Trump announced that he intended to nominate Jay Clayton, a Mergers & Acquisitions partner at Sullivan & Cromwell LLP, to succeed Mary Jo White as Chair of the SEC. According to his firm...more
On December 15, 2016, the Office of Foreign Assets Control revised its Frequently Asked Questions guidance that concerns the re-imposition of sanctions in the event of a sanctions snapback under the Joint Comprehensive Plan...more
Yesterday’s election has significant implications for international sanctions, particularly with respect to Iran, Cuba, and Russia. Although we do not want to be unduly alarmist, President-elect Trump’s statements on the...more