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Impact of Global Sanctions Regimes Relating to Russia, Ukraine, and Belarus

As a response to the Russian invasion of Ukraine starting in late February 2022, Australia, the European Union, Japan, the United Kingdom, the United States, and many other countries have progressively imposed increasingly...more

OFAC Issues Additional Ransomware Guidance and Designates Virtual Currency Exchange

The U.S. Treasury Department has issued an updated ransomware advisory that highlights sanctions risks associated with ransomware payments and details proactive steps companies can take to mitigate these risks....more

Prohibiting Compliance With Certain U.S. Sanctions—Advocate-General Grapples With EU Blocking Statute Catch-22

The Situation: The EU Blocking Statute prohibits EU operators from complying with certain U.S. sanctions, creating a Catch-22 for EU operators facing two directly opposing legal regimes. Important guidance on the precise...more

New Sanctions Target Additional Sectors of Iranian Economy

The Situation: The Trump administration announced a new round of sanctions on January 10, 2020, following escalating tensions between the United States and Iran. The Result: The new sanctions complement existing sanctions...more

Sanctions Enforcement Action Provides Incentives for Companies and a Warning for Individuals

The Situation: Using a novel approach, the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") concurrently designated a non-U.S. individual to the Foreign Sanctions Evaders ("FSE") List in connection...more

Impact of U.S. Withdrawal from the Iran Nuclear Deal

The Situation: On Tuesday, May 8, 2018, President Trump announced that the United States has withdrawn from the Iran Nuclear Deal and will fully reimpose its suspended sanctions targeting Iran. The Result: All currently...more

United States' Withdrawal From "Iran Deal" Will Reimpose Sanctions

On May 8, 2018, President Trump announced that the United States would cease participating in the Joint Comprehensive Plan of Action ("JCPOA"), commonly known as the Iran Deal. This will reimpose, by no later than November 5,...more

U.S. Sanctions Imposed on Russian Individuals, Associated Entities and Government Officials

The Situation: The Trump Administration has imposed sanctions against a number of high-profile Russian individuals and entities by adding them to the Specially Designated Nationals and Blocked Persons ("SDN") List. The...more

Trump Announces New Iran Strategy, Decertifies Iran's Compliance with Iran Nuclear Deal

On Friday, October 13, 2017, President Trump announced that he would not certify that the suspension of sanctions pursuant to the Joint Comprehensive Plan of Action ("JCPOA") (commonly known as the Iran Nuclear Deal) is...more

United States Revokes Sanctions on Sudan; Some Restrictions Remain in Place

On October 6, 2017, the United States announced that, effective October 12, 2017, it will substantially revoke sanctions on Sudan and the Government of Sudan in recognition of the Government of Sudan's sustained positive...more

With Tensions Rising, the United States Imposes Additional Sanctions on North Korea

In Short - The Situation: Over the past several months, North Korea has engaged in several activities, particularly relating to missile and nuclear testing, that violate several United Nations resolutions and that...more

Trump Administration Imposes Targeted Financial Sanctions on Venezuela

On August 24, 2017, President Donald Trump issued an Executive Order imposing new sanctions intended to restrict financing connected to the Government of Venezuela. These sanctions supplement existing sanctions imposed by the...more

President Trump Signs New Sanctions Legislation into Law

On August 2, 2017, President Trump signed the "Countering America's Adversaries Through Sanctions Act" ("Act") into law. The Act, which codifies and strengthens sanctions against Russia and expands sanctions against Iran and...more

President Trump Delays Decision on Sudanese Sanctions for Three Months

On July 11, 2017, President Trump issued an executive order that postpones any decision regarding whether to terminate the comprehensive sanctions regime against Sudan for an additional three months—until October 12, 2017....more

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