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OFAC Tightens Russia Sanctions; BIS Cracks Down on Diversion

On June 12, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced new measures targeting Russia’s financial infrastructure, including: 1. Expanding the scope of financial sanctions:...more

Say SoL Long to Short Limits: Doubling Down on the Sanctions Statute of Limitations

Effective April 24, the statute of limitations (“SoL”) under the International Emergency Economic Powers Act (“IEEPA”) and the Trading with the Enemy Act (“TWEA”) has been extended from five to ten years. It would have been...more

E(U)xterritoriality of EU Sanctions: The No Russia Clause

The EU is going extraterritorial, and it is doing so through private contract. It is a pretty neat trick. As a general rule, EU regulations do not apply extraterritorially. This policy is a bit pointed, intended to stand...more

U.S., UK and EU Sanctions Over Putin’s Recognition of Breakaway Ukraine Regions

U.S. Comprehensive Sanctions Against the DNR and the LNR - Scope: the DNR and LNR - The new EO does not detail which parts of the Donetsk and Luhansk regions[1] are subject to the new U.S. sanctions. It is likely that...more

Counterpunch: China Adopts Landmark Anti-Sanctions Statute to Stop U.S. Sanctions Effects Overseas

On June 10, 2021, China enacted the Anti-Foreign Sanctions Law (“AFSL”), aimed at punishing countries that impose anti-China sanctions and the companies that comply with those sanctions. The law is effective immediately, and...more

The EU – U.S. Sanctions Dilemma: The Advocate General of the European Court of Justice Weighs in

In May 2018 the United States announced the reinstitution of sanctions against Iran that had previously been lifted pursuant to the Joint Comprehensive Plan Action (“JCPOA”). The U.S. sanctions on Iran that were revived...more

U.S. Imposes Sanctions Measures Targeting Myanmar Military Government

On February 1, 2021, the Myanmar military overthrew the country’s democratically elected government and installed an army general as head of state, with a cadre of military officials and their allies running the government. ...more

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