Institutional investors, asset managers and others in the financial services industry increasingly are adopting environmental, social and governance (“ESG”) investment principles to attract and retain business from socially...more
6/3/2019
/ Antiboycott Requirements ,
Asset Management ,
Blacklist ,
Bureau of Industry and Security (BIS) ,
Disclosure Requirements ,
Divestiture ,
Economic Sanctions ,
Environmental Social & Governance (ESG) ,
EU ,
Financial Services Industry ,
Global Economy ,
Institutional Investors ,
Iran ,
IRS ,
Israel ,
Middle East ,
Popular ,
Public Pension ,
Publicly-Traded Companies ,
Sanction Violations ,
Securities and Exchange Commission (SEC) ,
Sudan ,
United Nations ,
United States
On November 5, 2018, applicable wind-down periods for certain transactions with Iran ended and the second and final set of U.S. secondary sanctions that had been lifted pursuant to the Iran nuclear deal – the Joint...more
11/7/2018
/ Blocking Statutes ,
Economic Sanctions ,
Energy Sector ,
EU ,
Exports ,
FinCEN ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
Petroleum ,
SDN List ,
Secondary Sanctions ,
Shipping ,
Special Purpose Vehicles ,
Trump Administration
As expected, following his May 8, 2018, decision to withdraw the United States from the Joint Comprehensive Plan of Action (“JCPOA”), President Trump signed a new Executive Order (“E.O.”) on August 6, 2018, formally...more
8/9/2018
/ Blocking Statutes ,
EU ,
Executive Orders ,
Financial Institutions ,
International Relations ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Nuclear Power ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Secondary Sanctions ,
Trump Administration ,
Winding Down ,
Withdrawal
The U.S. yesterday commenced the phased re-introduction of its pre-JCPOA extra-territorial sanctions in relation to Iran – with some measures applying immediately, and others from 5 November. The EU has condemned U.S....more
8/9/2018
/ Blocking Statutes ,
China ,
Economic Damages ,
EU ,
European Commission ,
Extraterritoriality Rules ,
Financing ,
Foreign Relations ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Member State ,
Notice Requirements ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Secondary Sanctions ,
Trump Administration
International sanctions are a major compliance challenge for companies worldwide. The regulatory risks associated with economic sanctions, asset-freezing measures and trade embargoes are not new, but they continue to grow in...more
7/19/2018
/ Blocking Statutes ,
Bonds ,
Cryptocurrency ,
Debt Buyers ,
Debt-Equity ,
Defense Sector ,
Economic Sanctions ,
Energy Sector ,
EU ,
Financial Markets ,
General Licenses ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Popular ,
Russia ,
SDN List ,
Secondary Sanctions ,
Syria ,
Trump Administration ,
Ukraine ,
Venezuela
The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) has tightened Iran sanctions. Specifically, OFAC revoked authorizations that (1) allowed foreign subsidiaries of U.S. companies to do business in Iran;...more
Following the U.S. decision to withdraw from the Joint Comprehensive Plan of Action (JCPOA) and reimpose sanctions on Iran, the EU has confirmed its full commitment to keep the agreement alive for the remaining parties, as...more
6/13/2018
/ Blocking Statutes ,
EU ,
European Commission ,
Exemptions ,
Foreign Relations ,
General Licenses ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Sanction Violations ,
Secondary Sanctions ,
Trade Relations ,
Trump Administration ,
Waivers ,
WTO
Yesterday, President Trump signed H.R. 3364, the “Countering America’s Adversaries Through Sanctions Act,” enacting into law limited additional sanctions against Russia and, critically, restricting his ability to suspend or...more
After weeks of discussion and procedural uncertainty, the U.S. House of Representatives passed new legislation by a vote of 419–3 that, if enacted into law, will strengthen existing sanctions against Russia and also impose...more
7/29/2017
/ Congressional Authority ,
Cyber Attacks ,
Economic Sanctions ,
Energy Sector ,
Foreign Relations ,
Hackers ,
Iran ,
Iran Sanctions ,
North Korea ,
Pending Legislation ,
Russia ,
SSI List ,
Trump Administration
On September 10, 2015, Senate Democrats in the U.S. Congress blocked a vote on a widely anticipated resolution to reject the Joint Comprehensive Plan of Action (“JCPOA”) regarding Iran’s nuclear program. On September 11, the...more
9/14/2015
/ Adoption Day ,
Asset Freeze ,
EU ,
Implementation Day ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Nuclear Power ,
Nuclear Weapons ,
Political Parties ,
UN Security Council ,
United Nations
Iran and the P5+1 countries (United States, Russia, China, United Kingdom, France and Germany) on 14 July 2015 announced their agreement on a comprehensive plan under which certain international sanctions against Iran will be...more
The UK HM Treasury (“HMT”) is changing its policy in relation to funds received in the UK that have come either directly or indirectly from an individual or entity outside of the EU that is subject to EU Sanctions (a...more
Recent enforcement actions brought by the U.S. Government against non-U.S. banks for violations of U.S. sanctions laws demonstrate the need for financial institutions, particularly those that act as custodians or financial...more
1/30/2014
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banks ,
Compliance ,
FinCEN ,
Foreign Banks ,
Iran ,
ITSR ,
Office of Foreign Assets Control (OFAC) ,
Sanctions ,
U.S. Treasury
Background -
Implementation of the Joint Action Plan agreed between the E3/EU+3 in October 2013 by suspending certain sanctions against Iran in relation to nuclear proliferation began on 20 January 2014. This...more