The U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) on August 8, 2022, imposed sanctions against the popular decentralized virtual currency mixer Tornado Cash alleging that it has been used to launder...more
9/16/2022
/ AML/CFT ,
Blockchain ,
Cyber Crimes ,
Data Privacy ,
Decentralized Finance (DeFi) ,
Ethereum ,
Financial Transactions ,
International Emergency Economic Powers Act (IEEPA) ,
Money Laundering ,
Office of Foreign Assets Control (OFAC) ,
Ransomware ,
Sanctions ,
SDN List ,
State Sponsors of Cyberattacks ,
U.S. Treasury ,
Virtual Currency ,
Wire Transfers
On April 15, 2021, the United States imposed new sanctions expanding restrictions on the purchase of certain Russian sovereign debt and other financing instruments and adding numerous Russian entities and individuals to the...more
Executive Summary - On March 2, 2021, the Biden Administration, in a coordinated announcement by the U.S. Departments of Treasury, State, and Commerce, tightened export restrictions against Russia and imposed sanctions and...more
3/4/2021
/ Biden Administration ,
Chemical Weapons ,
EU ,
Export Controls ,
Exports ,
Global Human Rights Sanctions Regime ,
Human Rights ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanctions ,
UK
President Vladimir Putin signed a bill on June 8, 2020 designed to provide legal recourse, in certain cases, to Russian (and foreign) persons who have been sanctioned by foreign states....more
While the rules regarding CFIUS review have remained largely unchanged over the past decade, CFIUS has operated under a new paradigm in recent years. After the U.S. government blocked just two transactions from its inception...more
6/21/2018
/ CFIUS ,
China ,
Corporate Counsel ,
Covered Transactions ,
Critical Infrastructure Sectors ,
Disparate Treatment ,
Export Controls ,
FIRRMA ,
Foreign Acquisitions ,
Foreign Direct Investment ,
Foreign Investment ,
Intellectual Property Protection ,
National Security ,
NDAA ,
Passive Investments ,
Pending Legislation ,
Real Estate Investments ,
Rollbacks ,
Sanctions ,
Telecommunications ,
Transfer of Control ,
Trump Administration ,
U.S. Commerce Department ,
ZTE
The U.S. Commerce and Treasury Departments announced on January 26, 2016, actions to ease certain restrictions on transactions involving Cuba. The new actions do not significantly expand the types of activities in which U.S....more
The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) added the Yuzhno-Kirinskoye Field, a Russian oil and gas field, to the Entity List on August 7, 2015. The action effectively prohibits all persons from...more
On July 30, 2015, the U.S. Government added dozens of Russian and Ukrainian individuals and entities to the Ukraine-related sanctions lists.1 U.S. officials have stated that these new additions are not an escalation of U.S....more
The spring and summer of 2014 saw the United States and European Union impose a range of sanctions relating to Ukraine and Russia in response to the series of events leading to the fall of the Yanukovyich government in...more
President Obama issued an Executive Order (the “Order”) on April 1, 2015 that authorizes financial sanctions against certain “persons” (including both individuals and entities) designated by the Treasury Secretary to be...more
The U.S. Government announced two major sanctions enforcement actions this week that reinforce the compliance challenges faced by both U.S. companies with international activities and non-U.S. companies subject to U.S....more
3/30/2015
/ Civil Monetary Penalty ,
Compliance ,
Criminal Penalties ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Guilty Pleas ,
International Emergency Economic Powers Act (IEEPA) ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
PayPal ,
Sanctions ,
Schlumberger ,
Settlement ,
Sudan
On 16 December 2014, President Obama announced that he will sign the Ukraine Freedom Support Act of 2014 (hereinafter the “Act”) into law. As discussed in our update dated 12 December 2014, the Act represents a potentially...more
As noted in previous updates, the United States and European Union continue to impose sanctions against Ukrainian and Russian individuals and entities as a result of the turmoil in Ukraine. On 11 December 2014, the US Senate...more
The EU adopted amendments to the current EU sanctions against Russia on 4 December 2014. These amendments are implemented via Council Regulation (EU) No 833/2014 (as amended) (“Regulation 833/2014”). They are intended to both...more
On 29 November 2014, the European Union (EU) published measures targeting additional individuals and organisations to be added to the scope of EU sanctions measures against Russia. These measures widen the EU sanctions in...more
Since March 2014, the United States and European Union have imposed multiple rounds of sanctions restricting certain activities with Russian and Ukrainian individuals and companies as a result of the ongoing crisis in...more
The United States and European Union implemented new sanctions against Russia on 12 September 2014 as a result of the ongoing crisis in Ukraine. While the new US and EU measures share many similarities, companies subject to...more
The U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) revised its guidance with respect to entities owned 50 percent or more in the aggregate by more than one blocked persons. The new guidance, issued on...more
In response to the recent round of sanctions and export restrictions imposed on Russia, Russian Federation President Putin signed a decree on 6 August 20141 (the “Decree”) effectively banning or limiting for a period of one...more
The European Union announced its intention to adopt a broad package of trade and economic sanctions against Russia, targeting access to EU capital markets, defence exports, energy related equipment and technology and...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
On July 16, 2014, the U.S. Government imposed additional sanctions against Russian and Ukrainian individuals and companies as a result of the ongoing crisis in Eastern Ukraine. In addition to adding five individuals and 11...more
On June 30, 2014, BNP Paribas SA (“BNPP”), the largest bank in France, pled guilty to conspiring to violate U.S. sanctions laws and agreed to pay a total of nearly $8.9 billion in criminal forfeiture and penalties to the U.S....more
In the context of an EU-wide review of export licensing for Russia, the UK Foreign Secretary William Hague announced in March 2014 that the UK Government would be suspending (i) all existing export licences and application...more
In response to recent events in Ukraine, the United States and European Union imposed yet another round of sanctions this week. In response, Russia is considering a number of countermeasures that may affect U.S. and EU...more