On June 3, 2021, President Biden issued an Executive Order to modify sanctions initially imposed by former President Trump regarding investments in Chinese companies with alleged ties to the Chinese military. The new...more
In this OnPoint, we discuss new rules announced by China’s Ministry of Commerce (“MOFCOM”) aimed at counteracting the extraterritorial impact of foreign law on Chinese persons. ...more
On December 28, 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) released guidance on the implementation of sanctions targeting securities of Communist Chinese military companies (“CCMCs”) imposed...more
The U.S.-China trade war continues to escalate, most recently fueled by U.S. concerns over China’s assertion of increasing authority over Hong Kong. The U.S. and Chinese governments have exchanged jabs through the use of...more
7/17/2020
/ CFIUS ,
China ,
Criminal Prosecution ,
Economic Sanctions ,
Exceptions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Free Speech ,
Free Trade Agreements ,
Freedom of the Press ,
Hong Kong ,
Hong Kong Autonomy Act (HKAA) ,
Human Rights ,
Open General Export Licences (OGELs) ,
Popular ,
Revocation ,
Right to Peaceful Assembly ,
SDN List ,
Section 301 ,
Tariffs ,
Technology Sector ,
Trade Act of 1974 ,
Trade Policy ,
Trade Wars ,
Travel Ban ,
Trump Administration ,
United States
Background -
The U.S. Government, through the Treasury Department’s Office of Foreign Assets Control (“OFAC”), has imposed comprehensive sanctions against Syria since 2011. ...more
The outbreak of COVID-19 is impacting international trade as global markets deal with uncertain supply and companies and governments work to ensure personal safety while developing contingency plans for handling the virus. In...more
3/12/2020
/ Breach of Contract ,
Bureau of Industry and Security (BIS) ,
Coronavirus/COVID-19 ,
Economic Sanctions ,
Export Controls ,
Exports ,
Force Majeure Clause ,
General Licenses ,
Humanitarian Assistance ,
Infectious Diseases ,
Medical Supplies ,
Multinationals ,
Office of Foreign Assets Control (OFAC) ,
Risk Management ,
Sanction Violations ,
Supply Chain
The U.S.Treasury Department’s Office of Foreign Assets Control (“OFAC”) added Rosneft Trading SA (“Rosneft Trading”), a subsidiary of Russian oil major Rosneft Oil Company (“Rosneft”), to the List of Specially Designated...more
2/25/2020
/ Crude Oil ,
Debt Instruments ,
Economic Sanctions ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Risk Assessment ,
Russia ,
Sanction Violations ,
SDN List ,
Secondary Sanctions ,
SSI List ,
U.S. Treasury ,
Venezuela ,
Winding Down
On December 13, 2019, the U.S. Department of Justice (“DOJ”) issued a new policy for companies that voluntarily disclose potential criminal violations of U.S. sanctions and export control laws to the DOJ’s National Security...more
12/21/2019
/ Aggravating Factors ,
Amended Rules ,
Bureau of Industry and Security (BIS) ,
Cooperation ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Exports ,
Foreign Corrupt Practices Act (FCPA) ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Remediation ,
Sanction Violations ,
Self-Disclosure Requirements ,
Successor Liability ,
Voluntary Disclosure
The U.S. State and Treasury Departments announced that a second round of sanctions will be imposed against Russia pursuant to the Chemical and Biological Weapons Control Act of 1991 (“CBW Act”). The most notable new measure...more
8/7/2019
/ Bank of Russia ,
Biological-Weapons ,
Bond Markets ,
Broker-Dealer ,
CBW Act ,
Chemical Weapons ,
Commodities Traders ,
Commodity Futures Contracts ,
Economic Sanctions ,
Financial Institutions ,
Foreign Banks ,
International Banks ,
Investment Companies ,
National Security ,
Open General Export Licences (OGELs) ,
Russia ,
Secondary Sanctions ,
Trump Administration ,
U.S. Treasury ,
US State Departments
After an unusually quiet year bringing enforcement cases in 2018, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has assumed an unprecedented pace in 2019 – since January 31, OFAC has...more
On April 25, 2019, Haverly Systems, Inc. (Haverly) agreed to pay a penalty of $75,375 to the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) to settle charges related to two violations of sanctions...more
4/30/2019
/ Compliance ,
Corporate Counsel ,
Economic Sanctions ,
Enforcement Actions ,
Goods or Services ,
Office of Foreign Assets Control (OFAC) ,
Payment Terms ,
Penalties ,
Russia ,
Sanction Violations ,
SSI List
Last week, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”), the EU Council, and Canada imposed further sanctions targeting Russian individuals and entities allegedly involved in the escalation of...more
3/22/2019
/ Australia ,
Banks ,
Blocked Entities ,
Blocked Person ,
CAATSA ,
Canada ,
CBW Act ,
Economic Sanctions ,
EU Council of Ministers ,
Executive Orders ,
Legislative Agendas ,
Liquid Natural Gas ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Popular ,
Russia ,
SDN List ,
Ukraine ,
US State Departments ,
Venezuela
On February 1, 2019, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued guidance in the form of Frequently Asked Questions (“FAQs”) relating to sanctions imposed on January 28, 2019 against...more
2/4/2019
/ Blocked Person ,
Bonds ,
Derivatives ,
Due Diligence ,
Economic Sanctions ,
General Licenses ,
Non U.S. Person ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
SDN List ,
Trump Administration ,
U.S. Treasury ,
Venezuela ,
Winding Down
On January 28, 2019, the United States imposed blocking sanctions on Petróleos de Venezuela SA (“PdVSA”), the Venezuelan state-owned oil company. The measures follow President Trump’s recent decision to recognize Juan Guaidó,...more
1/31/2019
/ Blocked Person ,
Economic Sanctions ,
Energy Sector ,
Executive Orders ,
Financial Institutions ,
Foreign Investment ,
Imports ,
International Emergency Economic Powers Act (IEEPA) ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Presidential Elections ,
SDN List ,
Trump Administration ,
Venezuela ,
Winding Down
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
On August 24, 2018, the U.S. Department of State announced a new but limited export licensing policy for defense and national security-sensitive goods and technology to Russia, effective August 27, 2018. The export licensing...more
8/27/2018
/ Chemical Weapons ,
Economic Sanctions ,
Export Controls ,
Exports ,
Financial Institutions ,
Foreign Exchanges ,
Foreign Subsidiaries ,
Government Officials ,
Legislative Agendas ,
National Security ,
Russia ,
State-Owned Enterprises ,
UK ,
US State Departments