The United States has substantially expanded economic sanctions and export controls targeting Russia and Belarus, imposing new restrictions that could have a major impact on companies with business activities in or relating...more
The 21st Century Peace Through Strength Act became law recently as part of H.R. 815, which also provided aid to Ukraine, Israel and Taiwan. The law contains important sanctions measures that: Extend the statute of...more
The United States has strengthened economic sanctions and export controls targeting Russia, following through on commitments made at a G7 summit this month. The EU and UK also plan to substantially expand measures targeting...more
Effective February 5, 2023, a coalition of G7 countries, Australia, and the European Union have generally forbidden service providers to provide certain services relating to the maritime transport of certain Russia-origin...more
Effective December 5, 2022, a coalition of G7 countries, Australia, and the European Union have generally forbidden service providers to provide certain services relating to the maritime transport of Russia-origin crude oil...more
12/6/2022
/ Australia ,
Economic Sanctions ,
EU ,
Exports ,
G7 ,
General Licenses ,
Maritime Transport ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Oil Prices ,
Russia
As part of its continuing response to Russia’s ongoing hostilities in Ukraine, the United States recently imposed additional sanctions and export controls targeting Russia...more
The United States, the European Union and the United Kingdom recently imposed new Russia-related sanctions in response to Russia’s continued hostilities in Ukraine...more
The United States and its allies continue to ramp up pressure on Russia and Belarus in response to Russia’s continued hostilities in Ukraine. In this alert, we describe the latest export, import, and investment bans and...more
Building on the “first tranche” of sanctions announced on February 22, 2022 described in our prior alert, the United States, the EU, the UK, and their allies have imposed (or announced the imposition of) additional...more
3/1/2022
/ Blocking Sanctions ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Financial Institutions ,
Financial Transactions ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SWIFT ,
Ukraine ,
Virtual Currency
In response to the Russian government’s recognition of the Donetsk and Luhansk People’s Republics of Ukraine (the “Covered Regions”) as states and deployment of Russian troops to the Covered Regions, the United States and its...more
On October 21, 2021, the Commerce Department’s Bureau of Industry and Security (“BIS”) published a rule that will restrict some exports, reexports, and other overseas transfers of equipment, software, and technology...more
On September 21, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced several actions focused on disrupting criminal digital finance infrastructure, including virtual currency...more
10/13/2021
/ Cryptocurrency ,
Cyber Attacks ,
Cybersecurity ,
Department of Justice (DOJ) ,
Digital Currency ,
Enforcement Actions ,
International Emergency Economic Powers Act (IEEPA) ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Ransomware ,
Risk Mitigation ,
Sanctions ,
SDN List ,
Virtual Currency
President Biden issued a new Executive Order 14024 (“E.O. 14024”) on April 15, 2021, expanding sanctions against Russia. E.O. 14024 authorizes, for the first time, U.S. sanctions against Russian technology companies and,...more
4/21/2021
/ Biden Administration ,
Crimea ,
Critical Infrastructure Sectors ,
Defense Sector ,
Economic Sanctions ,
Executive Orders ,
Financial Institutions ,
Foreign Policy ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanctions ,
SDN List ,
SolarWinds ,
Sovereign Debt ,
State-Owned Enterprises ,
Technology Contracts
In March 2021, three federal agencies promulgated international trade restraints as part of the Biden Administration’s response to alleged mistreatment of Russian opposition leader Alexey Navalny in 2020. Specifically, the...more
3/31/2021
/ Arms Embargo ,
Biden Administration ,
Bureau of Industry and Security (BIS) ,
CAATSA ,
Economic Sanctions ,
Energy Projects ,
Enforcement Actions ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Policy ,
Foreign Relations ,
Infrastructure ,
ITAR ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Russia ,
SDN List ,
Trade Restrictions ,
US Trade Policies ,
Vessels
The Office of Foreign Assets Control of the U.S. Treasury Department (“OFAC”) issued an extensive Fact Sheet on April 16, 2020 regarding the provision of humanitarian assistance and trade to combat COVID-19 in compliance with...more
4/17/2020
/ Economic Sanctions ,
Executive Orders ,
FEMA ,
Foreign Policy ,
Foreign Relations ,
Goods or Services ,
Humanitarian Assistance ,
Iran Sanctions ,
Medical Supplies ,
Office of Foreign Assets Control (OFAC) ,
Personal Protective Equipment
A recent federal criminal action shows the depth of the U.S. government’s concern about the use of cryptocurrency (or virtual currency) to violate economic sanctions laws and the lengths to which it will go to charge such...more
1/24/2020
/ Anti-Money Laundering ,
Bitcoin Mining ,
BSA/AML ,
CFTC ,
Corruption ,
Cryptocurrency ,
Currency Exchange ,
Digital Currency ,
Economic Sanctions ,
Financial Transactions ,
FinCEN ,
Geo-Blocking ,
Jurisdiction ,
Money Laundering ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Regulatory Oversight ,
Risk Management ,
Sanction Violations ,
SDN List ,
Securities and Exchange Commission (SEC) ,
Strict Compliance ,
Strict Liability ,
Virtual Currency
With new Iran-related sanctions, the U.S. government is making good on threats to give third-country companies a choice – participate in the U.S. market or participate in the Iranian market.
...more
1/13/2020
/ Aluminum Sales ,
Blocked Person ,
Critical Infrastructure Sectors ,
Economic Sanctions ,
Executive Orders ,
Foreign Corporations ,
Foreign Policy ,
Foreign Relations ,
Goods or Services ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
Steel Industry ,
Trump Administration ,
U.S. Treasury
As described in our prior alert, November 5, 2018 marked the full return ("snapback") of U.S. Iran-related sanctions measures lifted or waived pursuant to the Iran nuclear deal (the Joint Comprehensive Plan of Action or...more
11/13/2018
/ Economic Sanctions ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Goods or Services ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Trump Administration
In response to the latest U.S. economic sanctions, Russia adopted a law that gives the Russian President a broad authorization to retaliate for foreign sanctions. However, while this law makes a political statement, it does...more
Crucial Points -
Previously Lifted or Waived Sanctions Measures Coming Back Into Effect: On May 8, 2018, the U.S. President terminated U.S. participation in the Iran nuclear agreement. As a result, U.S. Iran-related...more
On April 6, 2018, the U.S. Treasury Department's Office of Foreign Assets Control ("OFAC") expanded U.S. sanctions relating to Russia by "blocking" seven prominent Russian businessmen, 12 companies, 17 senior Russian...more
On March 7, U.S. authorities settled criminal and civil proceedings involving Zhongxing Telecommunications Equipment Corporation and certain of its affiliates ("ZTE"). ZTE is the largest publicly traded telecommunications...more
3/17/2017
/ Bureau of Industry and Security (BIS) ,
China ,
Export Controls ,
Iran Sanctions ,
National Security ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Technology ,
Telecommunications ,
U.S. Commerce Department ,
ZTE
Last week, U.S. authorities settled criminal charges against a subsidiary of Schlumberger Ltd. and civil claims against PayPal, Inc. Federal authorities alleged that these companies violated U.S. embargoes and other economic...more
4/9/2015
/ Criminal Sanctions ,
Felonies ,
Iran ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
PayPal ,
Plea Agreements ,
Popular ,
Sanctions ,
Schlumberger ,
SDN List ,
Sudan ,
Syria