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U.S. Modifies and Solidifies Sanctions on Investments in Certain Chinese Companies

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

The U.S. and EU Coordinate Sanctions Related to Navalny Poisoning and Sentencing: Biden Administration’s First Sanctions Against...

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

OFAC Issues Guidance Indicating Aggressive Interpretation of China Military Company Sanctions

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

Trumps Bans Investments in Publicly Traded Securities of “Chinese Military Companies”

President Trump issued an Executive Order on November 12, 2020 that will prohibit U.S. persons from investing in publicly traded securities of certain companies determined to be affiliated with China’s military.  Executive...more

U.S. Expands Syria Sanctions By Targeting Non-U.S. Persons Who Support the Assad Regime

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

COVID-19: International Trade Navigation

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

Russia/Venezuela Sanctions Update: Additional Sanctions Imposed on Rosneft Trading 

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

DOJ Revised Policy on Voluntary Self-Disclosures of Sanctions and Export Violations

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

U.S. Imposes Blocking Sanctions on Government of Venezuela, Signals Additional Secondary Sanctions

On August 5, 2019, the President signed a new executive order ( “EO 13884”) that imposes blocking sanctions on the Government of Venezuela (“GOV”). EO 13884 does not impose a trade embargo or broadly prohibit transactions...more

OFAC Speaks Loudly, Carries a Bigger Stick

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

OFAC Imposes First Penalty for Russia Sectoral Sanctions Violations

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

U.S., EU, Canada and Australia Take Coordinated Action Targeting Russia as Congress Considers Further Sanctions

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

OFAC Clarifies, and Further Complicates, Sanctions on Venezuela, PdVSA

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

U.S. Escalates Sanctions Against PdVSA, Venezuela

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

End of the Road: U.S. Sanctions on Iran Come Back Into Effect

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

Iran Sanctions – U.S. Reimposes Sanctions After JCPOA Withdrawal, First Measures Come Into Effect

As expected, following his May 8, 2018, decision to withdraw the United States from the Joint Comprehensive Plan of Action (“JCPOA”), President Trump signed a new Executive Order (“E.O.”) on August 6, 2018, formally...more

The United States Tightens Iran Sanctions by Revoking Authorizations

The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) has tightened Iran sanctions. Specifically, OFAC revoked authorizations that (1) allowed foreign subsidiaries of U.S. companies to do business in Iran;...more

Iran Sanctions – President Trump’s Announcement of US Withdrawal from JCPOA

President Trump announced today, May 8, 2018, that the United States would withdraw from the Joint Comprehensive Plan of Action (“JCPOA”), the Iran nuclear deal implemented in January 2016. In connection with the...more

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