The US Office of Foreign Assets Control first issued the Syrian Sanctions on April 5, 2005, implementing Executive Order 13338, “Blocking Property of Certain Persons and Prohibiting the Export of Certain Goods to Syria.” On...more
The US government recently announced additional significant export controls and sanctions related to Russia and Belarus, including new export restrictions on EAR99 software, certain consumer communication devices, and...more
The US Department of Commerce’s Bureau of Industry and Security (BIS) released an interim final rule (IFR) on October 7, 2022, imposing additional export controls on certain advanced computing and semiconductor manufacturing...more
The United States, in concert with Western allies, has imposed sweeping sanctions on Russia in response to President Vladimir Putin’s action in Ukraine. In addition to a full suite of sanctions administered by the US...more
In connection with recent Russia-related sanctions issued by the US government, organizations face a variety of issues when navigating the questions of who and what transactions may be subject to the reach of these sanctions....more
Based on the evolving military operations of the Russian Federation in Ukraine, the United States has imposed additional sanctions on the Russian Federation, Russian leadership, and various financial institutions and...more
In response to the Russian Federation’s recognition of certain regions of Ukraine as independent states which followed an expansion of nearly 200,000 troops on the Ukrainian border, US President Joseph Biden authorized the...more
The new executive order continues the policy of prohibiting US persons’ transactions in the publicly traded securities of select Chinese companies, but expands the scope to include both Chinese companies that operate or have...more
6/9/2021
/ Biden Administration ,
China ,
Defense Sector ,
Economic Sanctions ,
Executive Orders ,
Financial Instruments ,
Foreign Policy ,
Human Rights ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Prohibited Transactions ,
Securities Transactions ,
Surveillance
The still evolving US sanctions (as well as the EU and now also separate UK sanctions) continue to challenge Russia-related business. The sanctions frameworks are complex, changing, and, at times, inconsistent as well as...more
3/23/2021
/ Bureau of Industry and Security (BIS) ,
CAATSA ,
Crimea ,
Economic Sanctions ,
EU ,
Foreign Policy ,
Infrastructure ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Russia ,
SDN List ,
UK ,
UK Brexit
President Trump’s Executive Order Addressing the Threat from Securities Investments that Finance Communist Chinese Military Companies (EO 13959) prohibits transactions by or on behalf of US persons in publicly traded...more
The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) published final rules on January 15, 2021, implementing the sanctions put in place by Executive Order 13936 (EO 13936) and the Hong Kong Autonomy Act...more
2/1/2021
/ China ,
Economic Sanctions ,
Executive Orders ,
Foreign Entities ,
Foreign Relations ,
General Licenses ,
Hong Kong ,
Hong Kong Autonomy Act (HKAA) ,
International Emergency Economic Powers Act (IEEPA) ,
National Security ,
Office of Foreign Assets Control (OFAC)
The new Executive Order (EO or the Order) bans transactions by US persons in publicly traded securities of companies identified as “Chinese military companies,” and includes a ban on trading in derivatives of those securities...more
11/18/2020
/ China ,
ETFs ,
Executive Orders ,
Foreign Policy ,
Foreign Relations ,
International Emergency Economic Powers Act (IEEPA) ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Prohibited Transactions ,
Publicly-Traded Companies ,
Securities Transactions ,
Trump Administration
The US Secretary of the Treasury announced sanctions this summer on 11 individuals who the Secretary views as being involved in implementing the recently enacted Law of the People’s Republic of China on Safeguarding National...more
United States -
Various threats of further broad sanctions… triggered by ongoing negative developments and perceptions in the US-Russia relationship – though new sanctions legislation seems unlikely before the 3 Nov. US...more
10/7/2020
/ CAATSA ,
Crimea ,
Economic Sanctions ,
EU ,
Exports ,
Foreign Relations ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Trade Relations ,
UK ,
UK Brexit ,
US Trade Policies
This presentation, an update to our April 2020 presentation, highlights the most recent developments and then provides a detailed overview of the relevant frameworks and their possible implications—including a focus on the...more
7/30/2020
/ CAATSA ,
Crimea ,
Economic Sanctions ,
EU ,
Foreign Policy ,
Foreign Relations ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Russia ,
SDN List ,
UK Brexit
President Donald Trump issued Executive Order 13936 on July 14 titled “The President’s Executive Order on Hong Kong Normalization” (the Executive Order or EO 13936). On the same day, the Hong Kong Autonomy Act (HR 7440) was...more
7/29/2020
/ China ,
Economic Sanctions ,
Executive Orders ,
Hong Kong ,
Hong Kong Autonomy Act (HKAA) ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Preferential Trade Status ,
Risk Management ,
SDN List ,
Trump Administration
US persons who have engaged in wind-down or maintenance transactions with EN+ Group, UC Rusal, or JSC EuroSibEnergo (or entities they own or control) pursuant to General License 14E or 16E must report those transactions to...more
The Office of Foreign Assets Control recently designated 7 “oligarchs,” 17 government officials, 13 companies, and one bank, all Russian, as Specially Designated Nationals (SDNs), effectively prohibiting US persons...more
The new sanctions fall within the framework of existing US sanctions against Russia, but have expanded their application by classifying new, prominent individuals and companies as “Specially Designated Nationals.” Given the...more
Can the US government criminally prosecute non-US persons for activities that constitute secondary Iranian sanctions violations with no alleged nexus to the United States?...more
Though intended to avoid stifling trade in existing Venezuelan government bonds, the sanctions include restrictions on dealings in certain bonds that could impact bond holders....more
Changes to unwind will not take effect until new regulations are issued.
On June 16, US President Donald Trump announced his decision to revoke some—but not all—of the relaxations in Cuba sanctions initiated under former...more