The Situation: The EU Blocking Statute prohibits EU operators from complying with certain U.S. sanctions, creating a Catch-22 for EU operators facing two directly opposing legal regimes. Important guidance on the precise...more
Ambiguous, undefined terms create uncertainty and confusion, including whether owned or controlled subsidiaries of U.S. companies outside the United States are subject to this reporting requirement.
On June 21, the...more
Companies in the banking/financial, energy, logistics, and shipping sectors should assess their operations to mitigate sanctions compliance risks.
On Monday, April 22, 2019, the Trump Administration announced that, in the...more
The Situation: Using a novel approach, the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") concurrently designated a non-U.S. individual to the Foreign Sanctions Evaders ("FSE") List in connection...more
The Situation: On Tuesday, May 8, 2018, President Trump announced that the United States has withdrawn from the Iran Nuclear Deal and will fully reimpose its suspended sanctions targeting Iran.
The Result: All currently...more
5/14/2018
/ Economic Sanctions ,
Exporters ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
General Licenses ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
National Security ,
Nuclear Weapons ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Trump Administration ,
TSRA
On May 8, 2018, President Trump announced that the United States would cease participating in the Joint Comprehensive Plan of Action ("JCPOA"), commonly known as the Iran Deal. This will reimpose, by no later than November 5,...more
5/10/2018
/ Economic Sanctions ,
EU ,
Export Controls ,
Foreign Policy ,
General Licenses ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Trump Administration
On Friday, October 13, 2017, President Trump announced that he would not certify that the suspension of sanctions pursuant to the Joint Comprehensive Plan of Action ("JCPOA") (commonly known as the Iran Nuclear Deal) is...more
On August 2, 2017, President Trump signed the "Countering America's Adversaries Through Sanctions Act" ("Act") into law. The Act, which codifies and strengthens sanctions against Russia and expands sanctions against Iran and...more
8/8/2017
/ Congressional Override ,
Economic Sanctions ,
Energy Sector ,
Exports ,
Financial Services Industry ,
Foreign Relations ,
Imports ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Russia ,
SDN List ,
SSI List ,
State-Owned Enterprises ,
Trump Administration