On September 2, 2022, the G7 Finance Ministers issued a statement confirming their intention to implement a price cap with respect to Russian-origin crude oil and petroleum products in response to Russia’s continued invasion...more
9/8/2022
/ Crude Oil ,
Economic Sanctions ,
EU ,
G7 ,
Importers ,
Imports ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Pipelines ,
Pricing ,
Russia ,
Ukraine
Over the past few weeks, the US Department of Treasury Office of Foreign Assets Control (OFAC) took various actions in response to Russia’s continued invasion in Ukraine:
..updated the Specially Designated Nationals and...more
8/17/2022
/ Asset Freeze ,
Belarus ,
Belarus Sanctions ,
Blocked Entities ,
Blocked Person ,
Economic Sanctions ,
Entity List ,
Export Controls ,
General Licenses ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Russia ,
SDN List ,
Ukraine
Over the past few weeks, the US Department of the Treasury Office of Foreign Assets Control (OFAC) took additional actions in response to Russia’s continued invasion of Ukraine:
..Removed Kazakh subsidiary of Alfa Bank,...more
The US continues to ramp up sanctions pressure on Russia, now emphasizing Russian efforts to evade US export controls and obligations of financial institutions to police Russian efforts at sanctions and export controls...more
7/6/2022
/ Asset Freeze ,
Belarus ,
Belarus Sanctions ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Entity List ,
EU ,
Export Controls ,
Exports ,
FinCEN ,
Foreign Relations ,
General Licenses ,
Military Conflict ,
Oil & Gas ,
Russia ,
Switzerland ,
Trade Restrictions ,
UK ,
Ukraine
The Uyghur Forced Labor Prevention Act (the UFLPA) came into effect last week, and US Customs and Border Protection (CBP) and US Department of Homeland Security (DHS) have released guidance for importers for demonstrating...more
7/5/2022
/ Biden Administration ,
China ,
Compliance ,
Customs and Border Protection ,
Department of Homeland Security (DHS) ,
Effective Date ,
Entity List ,
Forced Labor ,
Importers ,
Imports ,
New Guidance ,
Rebuttable Presumptions ,
Supply Chain ,
Uyghur Forced Labor Prevention Act (UFLPA)
Following the invasion of Ukraine by Russia, the UK, EU and US have all responded by announcing significant sanctions in respect of Russia and Belarus.
This briefing summarises the key developments since 25 April 2022 and...more
Asset Freezes -
On 13 and 14 April 2022, the UK imposed asset freezes with respect to 208 individuals. This included alleged separatists, oligarchs, close associates and employees of oligarchs and individuals who have...more
After reports of humanitarian atrocities and further details of the continued Russian aggression in Ukraine emerged over the weekend, the United States and its allies responded with further sanctions and export controls. “The...more
During the past week, the US continued to strengthen its sanctions against Russia as Russia continued its invasion of Ukraine.
..BIS issued a final rule clarifying which luxury goods are subject to the ban on exports to...more
3/28/2022
/ Asset Freeze ,
Belarus ,
Economic Sanctions ,
EU ,
Export Controls ,
Exports ,
General Licenses ,
Imports ,
Russia ,
Trade Restrictions ,
UK ,
Ukraine
Following the invasion of Ukraine by Russia, the UK, EU and US have all responded by announcing significant sanctions in respect of Russia and Belarus.
The sanctions landscape has been changing at a fast pace and further...more
3/23/2022
/ Asset Freeze ,
Belarus ,
Blocked Entities ,
Blocked Person ,
Economic Sanctions ,
Entity List ,
EU ,
Export Controls ,
Foreign Relations ,
General Licenses ,
Russia ,
SDN List ,
Switzerland ,
UK ,
Ukraine
On March 7, 2022, the Financial Crimes Enforcement Network (FinCEN) issued an alert calling on financial institutions to be “vigilant” in guarding against attempts to evade the recent imposition of expanded Russia sanctions....more
3/21/2022
/ Anti-Money Laundering ,
Compliance ,
Economic Sanctions ,
Financial Institutions ,
FinCEN ,
Office of Foreign Assets Control (OFAC) ,
Reporting Requirements ,
Risk Management ,
Russia ,
Terrorist Financing Regulations ,
Virtual Currency
In the latest action to expand sanctions against Russia in response to its invasion of Ukraine, on March 8, 2022, President Biden announced in a televised speech a ban on imports of Russian oil, natural gas, and coal into the...more
3/11/2022
/ Biden Administration ,
Economic Sanctions ,
Executive Orders ,
Foreign Relations ,
General Licenses ,
Imports ,
Magnitsky Act ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Russia ,
Tariffs ,
WTO
The US Department of the Treasury (Treasury) has released the results of its review of economic and financial sanctions first announced in December 2020 by then President-elect Biden (Report). From that review, Treasury has...more
On September 21, 2021, the US Department of the Treasury took actions in response to the increasing prevalence and severity of ransomware attacks in the United States and address the central role that virtual currency and...more
9/27/2021
/ Currency Exchange ,
Cybersecurity ,
Cybersecurity Information Sharing Act (CISA) ,
Digital Currency ,
Economic Sanctions ,
Enforcement Actions ,
Office of Foreign Assets Control (OFAC) ,
Ransomware ,
SDN List ,
U.S. Treasury ,
Virtual Currency
On Monday, August 9, 2021, the Office of Foreign Assets Control (OFAC) of the US Department of the Treasury issued a multitude of sanctions designations affecting dealings with Belarusian companies in the construction, oil,...more
In 2019, the US imposed sanctions against China in reaction to “serious human rights abuse against ethnic minorities in Xinjiang...” The sanctions followed reports of mass arbitrary detention and severe physical abuse, among...more
6/16/2021
/ Biden Administration ,
China ,
Economic Sanctions ,
Exports ,
Forced Labor ,
Human Rights ,
Office of Foreign Assets Control (OFAC) ,
Rare Earth Metals ,
SDN List ,
Slavery ,
Solar Panels ,
Supply Chain
On June 3, 2021, in one of his first major China-related actions, President Biden issued an Executive Order that amends, but keeps intact the core elements of, previous orders issued by President Trump prohibiting US Persons...more
6/7/2021
/ Biden Administration ,
China ,
Department of Defense (DOD) ,
Exemptions ,
Foreign Investment ,
Human Rights ,
Military End Use ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Prohibited Transactions ,
SDN List ,
Technology Sector ,
Telecommunications ,
U.S. Treasury
While the Biden Administration desires a “stable and predictable” relationship with Russia, it has now made it clear that it will take “actions to impose costs on Russia for actions by its government and intelligence services...more
4/22/2021
/ Biden Administration ,
Blocked Entities ,
Blocked Person ,
Blocking Sanctions ,
Crimea ,
Economic Sanctions ,
Executive Orders ,
Foreign Policy ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia
On March 25, 2021, in its effort to intensify international pressure on Min Aung Hlaing’s military government, the US placed sanctions, pursuant to Executive Order 14014, on two holding companies, Myanma Economic Holdings...more
Xiaomi Corporation (Xiaomi), one of the world’s largest smartphone manufacturers, won a preliminary injunction from the DC District Court on March 12, 2021 that enjoined the US government from enforcing a Trump-era rule that...more
In the latest of a series of measures targeting China before this week’s transition of administrations, on January 14, 2021, the Trump Administration added China National Offshore Oil Corporation Ltd. (CNOOC) to the US...more
In a parting move to maximize sanctions pressure on China, on December 18, 2020, the Trump Administration added 59 Chinese entities to the United States (US) Commerce Department “Entity List,” imposing comprehensive controls...more
On December 14, 2020, the United States (US) imposed sanctions on Turkey pursuant to Countering America’s Adversaries Through Sanctions Act (CAATSA) for “knowingly engaging in a significant transaction with Rosoboronexport...more
In near lightning speed, Congress now has passed, and the President is expected to imminently sign into law, the Holding Foreign Companies Accountable Act (HFCAA), a bipartisan piece of legislation that, while applicable more...more
12/4/2020
/ Audits ,
China ,
Controlled Foreign Corporations ,
Corporate Governance ,
Delisting ,
Foreign Jurisdictions ,
Investors ,
Listing Standards ,
New Legislation ,
PCAOB ,
Publicly-Traded Companies ,
Securities and Exchange Commission (SEC) ,
Stock Exchange
On November 12, 2020, President Trump issued an executive order (Order) that effectively prohibits US persons from transacting in publicly traded securities of Chinese firms determined by the US government to be owned or...more