In light of the recent referendums and purported annexation by Russia of four territories of Ukraine on September 30, 2022, the United States, United Kingdom and European Union have expanded measures and provided additional...more
10/14/2022
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
EU ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Foreign Policy ,
Foreign Relations ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
UK ,
Ukraine
Even though significant sanctions and export controls have already been put in place, the United States recently adopted additional measures targeting key elements of the Russian economy and military industry in response to...more
Since the publication of our March 24, 2022, and March 17, 2022, client alerts, the U.S., U.K. and European Union, among other allied nations, have imposed additional sanctions and export controls on key elements of the...more
5/2/2022
/ Blocking Sanctions ,
Economic Sanctions ,
EU ,
European Commission ,
Export Controls ,
Exports ,
Financial Institutions ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
UK
On March 11, 2022, President Joe Biden signed Executive Order 14068 (E.O. 14068) imposing new restrictions on imports and exports with respect to Russia as well as on the supply of U.S. dollar-denominated banknotes to the...more
3/22/2022
/ Bank Notes ,
Banks ,
Biden Administration ,
Economic Sanctions ,
Executive Orders ,
Export Controls ,
Exports ,
Financial Institutions ,
Luxury Goods ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Ukraine
On March 8, 2022, President Joe Biden issued Executive Order (E.O.) 14066, which bans the import of Russian oil, gas and other energy products into the United States and imposes sweeping prohibitions on new U.S. investment in...more
Since the publication of our February 26, 2022, client alert, the United States, United Kingdom and the European Union, among other allied nations, have imposed additional sanctions and export controls on key elements of the...more
3/10/2022
/ Belarus ,
Blocking Sanctions ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Controls ,
Financial Institutions ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
SWIFT ,
Ukraine
The United States, United Kingdom and the European Union, among other allies, have moved swiftly in response to the Russian Federation’s invasion of Ukraine. Merely hours after Russia’s announcement on February 21, 2022, that...more
On October 15, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued detailed guidance to the virtual currency industry, putting virtual currency companies on notice of the ways OFAC...more
On October 18, 2021, the U.S. Department of the Treasury released the results of its broad review of economic and financial sanctions. The review, initiated by the Biden administration, included discussions with Congress,...more
In recent months, the increased focus on cryptocurrency regulation and enforcement at both the federal and state levels demonstrates the digital currency’s place as an established component of the financial landscape. At the...more
10/1/2021
/ Anti-Money Laundering ,
Bank Secrecy Act ,
BitMEX ,
Blockchain ,
CFTC ,
Cryptocurrency ,
Decentralized Finance (DeFi) ,
Department of Justice (DOJ) ,
Digital Assets ,
Digital Currency ,
FinCEN ,
Homeland Security Cybersecurity & Infrastructure Security Agency (CISA) ,
IRS ,
Office of Foreign Assets Control (OFAC) ,
Ransomware ,
Reporting Requirements ,
Securities and Exchange Commission (SEC)
On June 3, 2021, President Joe Biden issued Executive Order 14032 (EO 14032) amending and, in effect, recasting Executive Order 13959 of November 12, 2020 (EO 13959), which restricted U.S. persons from purchasing and selling...more
Sanctions -
The Biden administration has made clear that economic sanctions will continue to be an important U.S. foreign policy tool and has initiated a comprehensive review of current sanctions policies and practices....more
On April 15, 2021, President Joe Biden issued Executive Order 14024, titled the “Executive Order on Blocking Property With Respect to Specified Harmful Foreign Activities of the Government of the Russian Federation,” which...more
Rapidly growing interest in nonfungible tokens (NFTs) has been fueled by recent headlines of multimillion-dollar transactions, such as the $69 million sale of an NFT by digital artist Beeple — the third-highest price ever...more
In response to the February 1, 2021, military coup in Burma (Myanmar), on February 10, 2021, President Joe Biden issued Executive Order 14014 (EO 14014), “Executive Order on Blocking Property With Respect to the Situation in...more
On November 12, 2020, President Trump signed Executive Order 13959 prohibiting U.S. persons from engaging in any transaction in publicly traded securities in “Communist Chinese military companies” (CCMCs), effective January...more
11/18/2020
/ Biden Administration ,
China ,
Department of Defense (DOD) ,
Executive Orders ,
Foreign Relations ,
National Security ,
NDAA ,
Office of Foreign Assets Control (OFAC) ,
Publicly-Traded Companies ,
Securities Transactions ,
Trump Administration
On August 31, 2020, the Office of Information and Regulatory Affairs (OIRA), within the Office of Management and Budget (OMB), issued a memorandum to all executive departments and agencies on reforming regulatory enforcement...more
10/14/2020
/ Administrative Proceedings ,
Best Practices ,
Burden of Proof ,
CFTC ,
Civil Liability ,
Civil Monetary Penalty ,
Criminal Penalties ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Executive Orders ,
FinCEN ,
Office of Foreign Assets Control (OFAC) ,
OMB ,
Publicly-Traded Companies ,
Regulatory Oversight ,
Securities and Exchange Commission (SEC) ,
Standard of Review
In the wake of China’s new national security law for Hong Kong that went into effect on June 30, 2020, the Trump administration has taken several steps to significantly pare back Hong Kong’s preferential status under U.S....more
7/20/2020
/ Bureau of Industry and Security (BIS) ,
China ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Financial Institutions (FFI) ,
Foreign Persons ,
Hong Kong ,
Hong Kong Autonomy Act (HKAA) ,
Human Rights ,
Office of Foreign Assets Control (OFAC) ,
Preferential Trade Status ,
Revocation ,
Risk Assessment ,
Rollbacks ,
Trump Administration ,
U.S. Commerce Department ,
US Trade Policies
Addressing the Evolving Risks -
Warren Buffett said that “only when the tide goes out do you discover who’s been swimming naked.” Buffett was not talking about compliance programs in a time of crisis, but his wisdom applies...more
5/2/2020
/ Anti-Corruption ,
Anti-Money Laundering ,
BSA/AML ,
Compliance ,
Coronavirus/COVID-19 ,
Corporate Misconduct ,
Cybersecurity ,
Disclosure Requirements ,
Economic Sanctions ,
Enforcement Actions ,
FFIEC ,
Financial Distress ,
Financial Fraud ,
FinCEN ,
Foreign Corrupt Practices Act (FCPA) ,
Market Manipulation ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Public Health Emergency ,
Publicly-Traded Companies ,
Risk Assessment ,
Risk Mitigation ,
Sanction Violations ,
Securities and Exchange Commission (SEC)
In light of Turkey’s military intervention in northeast Syria, President Donald Trump issued, on October 14, 2019, Executive Order 13894 (EO 13894), “Blocking Property and Suspending Entry of Certain Persons Contributing to...more
10/21/2019
/ Blocked Person ,
Economic Sanctions ,
Executive Orders ,
Foreign Financial Institutions (FFI) ,
General Licenses ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Secondary Sanctions ,
Steel Industry ,
Syria ,
Tariffs ,
Trump Administration ,
Turkey
This issue of Skadden’s semiannual Cross-Border Investigations Update takes a close look at recent cases, regulatory activity and other key developments, including a review of the first year of GDPR enforcement, analysis of...more
10/3/2019
/ Anti-Money Laundering ,
Appeals ,
Blocking Statutes ,
Bribery ,
CFTC ,
China ,
CLOUD Act ,
Communication Restrictions ,
Compliance ,
Conspiracies ,
Cooperation Agreement ,
Crime (Overseas Production Orders) Act 2019 (the COPO Act) ,
Criminal Prosecution ,
Cross-Border Transactions ,
Cryptocurrency ,
Cybersecurity ,
Deferred Prosecution Agreements ,
Denial of Certiorari ,
Department of Justice (DOJ) ,
Deutsche Bank ,
Disclosure ,
Dodd-Frank ,
Economic Sanctions ,
Enforcement Actions ,
EU ,
EURIBOR ,
Exports ,
Extradition ,
Extraterritoriality Rules ,
Financial Conduct Authority (FCA) ,
Financial Records ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Exchanges ,
France ,
Fraud ,
General Data Protection Regulation (GDPR) ,
Government Investigations ,
Hackers ,
Hungary ,
Imports ,
India ,
Indictments ,
Information Sharing ,
Iran Sanctions ,
Israel ,
Lithuania ,
Money Laundering ,
Morrison v National Australia Bank ,
Multinationals ,
Office of Foreign Assets Control (OFAC) ,
Opioid ,
Pharmaceutical Industry ,
Popular ,
Rate-Rigging ,
SCOTUS ,
Securities and Exchange Commission (SEC) ,
Serious Fraud Office (SFO) ,
Spoofing ,
Subpoenas ,
Swiss Supreme Court ,
Switzerland ,
Tax Crimes ,
Tax Evasion ,
Tax Treaty ,
Turkey ,
UK ,
United States ,
Venezuela ,
Wal-Mart
In 2018, the United States continued to expand its sanctions programs and increase enforcement. While President Donald Trump’s decision to re-impose nuclear-related sanctions on Iran has perhaps drawn the most attention, key...more
1/23/2019
/ Blocked Entities ,
Blocked Person ,
Cryptocurrency ,
Cuba ,
Economic Sanctions ,
Executive Orders ,
Foreign Policy ,
General Licenses ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Nicaragua ,
Nuclear Power ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanction Violations ,
SDN List ,
Secondary Sanctions ,
Trump Administration ,
Venezuela ,
Withdrawal
On November 5, 2018, the United States reimposed all remaining nuclear-related sanctions against Iran that it had previously lifted in connection with its implementation of the Joint Comprehensive Plan of Action (JCPOA) in...more
11/13/2018
/ Cross-Border Transactions ,
Economic Sanctions ,
Executive Orders ,
Financial Institutions ,
Iran ,
Iran Sanctions ,
ITSR ,
Joint Comprehensive Plan of Action (JCPOA) ,
Nuclear Power ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
SDN List ,
Secondary Sanctions ,
Trump Administration ,
Winding Down ,
Withdrawal
The U.S. government recently took several actions involving the Venezuela- and Russia-related sanctions. On May 21, 2018, following the re-election of President Nicolás Maduro, President Donald Trump issued an executive order...more
On May 8, 2018, President Donald Trump announced that the United States was withdrawing from its participation in the Joint Comprehensive Plan of Action (JCPOA), the agreement the P5+1 (the United States, China, France,...more
5/15/2018
/ Economic Sanctions ,
EU ,
General Licenses ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Presidential Memorandum ,
Rescission ,
SDN List ,
Secondary Sanctions ,
Trump Administration ,
Winding Down