On Wednesday, March 11, 2020, following the World Health Organization’s announcement officially designating COVID-19 a pandemic, President Trump issued Proclamation 9993 suspending entry into the United States of certain...more
As we discussed in our last alert, Congress has exhibited increased willingness to consider imposing sanctions in order to advance US foreign policy interests. Multiple sanctions-related bills are currently under...more
Under the Senior Managers and Certification Regime (“SMCR”), firms are required to identify and report to the FCA any instances of disciplinary action taken in relation to conduct that would amount to a breach of one of the...more
2/10/2020
/ Artificial Intelligence ,
Banking Sector ,
Blockchain ,
Bribery ,
Cartels ,
Corporate Governance ,
Corporate Misconduct ,
Environmental Social & Governance (ESG) ,
EU ,
Financial Conduct Authority (FCA) ,
Financial Institutions ,
Financial Services Industry ,
Hong Kong Securities and Futures Commission (HKSFC) ,
Insurance Industry ,
Payment Systems ,
Risk Management ,
SMCR ,
Technology ,
UK ,
United Arab Emirates (UAE) ,
Whistleblower Protection Policies
The new Iran sanctions imposed by the Trump Administration are not the only recent sanctions actions of note. Congress has also shown its willingness to use sanctions as a foreign policy tool, with certain sanctions...more
1/23/2020
/ Asset Freeze ,
Blocking Sanctions ,
Congressional Committees ,
Defense Sector ,
Drug Trafficking ,
Economic Sanctions ,
Iran ,
Iran Sanctions ,
NDAA ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Opioid ,
Pipelines ,
Procurement Guidelines ,
Syria ,
Venezuela
On January 10, 2020, the US Administration announced the imposition of new sanctions against Iran. The sanctions were initially announced in President Trump’s public address on January 8, 2020, in the aftermath of Iran’s...more
On December 13, 2019, the US Department of Justice (DOJ) issued an update to its 2016 guidance regarding enforcement in export control and sanctions investigations of businesses. The updated policy now offers voluntary...more
12/20/2019
/ Compliance ,
Cooperation ,
Criminal Investigations ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Export Controls ,
Financial Institutions ,
Government Investigations ,
Guidance Update ,
National Security ,
Remediation ,
Terrorism Funding ,
Voluntary Disclosure
The US Department of State, as part of its system modernization effort, is continuing its roll out of the Defense Export Control and Compliance System (DECCS) next month. DECCS is set to become the central online platform...more
On August 19, 2019, the Department of Commerce, Bureau of Industry and Security (BIS) continued its actions restricting access by Huawei and certain of its non-US affiliates to goods, software and technology that are subject...more
In a show of support for Venezuelan Interim President Juan Guaidó last week, and in opposition to the Maduro regime, President Trump issued Executive Order 13884, which imposes blocking sanctions on the Government of...more
The Trump Administration announced last week that the US Government has added Huawei to the Commerce Department Entity List and, as of May 20, 2019, has announced a temporary general license for certain transactions. Here is...more
5/22/2019
/ China ,
Economic Sanctions ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Huawei ,
Licensing Rules ,
National Security ,
Supply Chain ,
Telecommunications ,
Trump Administration ,
U.S. Commerce Department
How should we approach competing sanctions risks?
Among the numerous regulatory compliance risks faced by financial institutions, economic and trade sanctions risks commonly receive a great deal of attention....more
4/8/2019
/ Blocking Statutes ,
CAATSA ,
Criminal Liability ,
Criminal Prosecution ,
Cuba ,
Economic Sanctions ,
Enforcement Actions ,
EU ,
Financial Institutions ,
Foreign Financial Institutions (FFI) ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
SDN List
Pursuant to the President’s May 8, 2018, memorandum announcing the United States’ withdrawal from the Joint Comprehensive Plan of Action (JCPOA), the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC)...more
1/3/2019
/ Blocking Statutes ,
Cuba ,
EU ,
Export-Import Bank of the US ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Trump Administration ,
U.S. Treasury ,
US Trade Policies
Effective October 12, 2017, the U.S. Government has revoked its sanctions against Sudan that were established in Executive Orders 13067 and 13412 and removed a number of Sudanese entities from the SDN List. The revocation...more
On September 20, 2017, President Trump issued Executive Order 13810 setting forth measures intended to further isolate North Korea through the imposition of additional sanctions on North Korean persons and on persons doing...more
President Trump signed into law the Countering America’s Adversaries Through Sanctions Act (the CAATS Act) on August 2, 2017. The CAATS Act impacts sanctions related to Russia, Iran and North Korea....more
Catching many by surprise, President Obama issued an Executive Order on Friday, January 13, 2017, which provides for the lifting of sanctions against Sudan in six months. In addition, OFAC published on Tuesday (January 17,...more
The long-awaited definitions rules have finally arrived as part of Export Control Reform. But wait, they’re not all there—the definitions, that is. While Commerce addressed essentially all of the items included in its last...more
Making regular updates to policies and procedures related to international trade compliance has always been an important aspect of ensuring their effectiveness, and particularly in light of the myriad changes to various U.S....more
3/21/2016
/ Corporate Counsel ,
Cuba ,
Cuban Assets Control Regulations (CACR) ,
Export Administration Regulations (EAR) ,
Export Controls ,
Multinationals ,
North Korea ,
Policies and Procedures ,
Popular ,
Sanctions ,
Travel Permits