Key Points
- On November 12, 2020, President Trump issued a new EO prohibiting U.S. persons from engaging in transactions in publicly traded securities of certain CCMCs, or any securities that are derivative of, or are...more
1/4/2021
/ China ,
Department of Defense (DOD) ,
Derivatives ,
Executive Orders ,
Financial Instruments ,
NDAA ,
Office of Foreign Assets Control (OFAC) ,
Private Equity ,
Publicly-Traded Companies ,
SDN List ,
Trade Relations ,
Trump Administration ,
US Trade Policies
• On October 23, 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) removed the two Turkish government ministries and three ministers that it added to its Specially Designated Nationals and...more
10/25/2019
/ Blocked Person ,
Economic Sanctions ,
Executive Orders ,
Foreign Policy ,
Foreign Relations ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Syria ,
Trump Administration ,
Turkey
• A new Executive Order signed October 14, 2019, authorizes U.S. sanctions related to the military conflict between Turkey and Syria, providing broad authority to impose sanctions against Turkish government agencies,...more
On September 9, 2019, the Trump administration implemented additional U.S. sanctions on Cuba by restricting personal remittances to Cuba and eliminating authorization for U.S. banks to process “U-turn” transactions involving...more
9/11/2019
/ Banking Sector ,
Cross-Border Transactions ,
Cuba ,
Cuban Assets Control Regulations (CACR) ,
Economic Sanctions ,
Foreign Policy ,
Fund Transfers ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Personal Remittance Caps ,
Trump Administration ,
U-Turn Transactions ,
U.S. Treasury
• In a further escalation of U.S. sanctions on Venezuela in support of its efforts to oust the regime of Nicolás Maduro, on August 5, 2019, the Trump administration imposed comprehensive sanctions on the Government of...more
8/19/2019
/ Banking Sector ,
Blocked Entities ,
Blocked Person ,
Economic Sanctions ,
Executive Orders ,
Financial Institutions ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Trump Administration ,
Venezuela
• The U.S. Department of State and the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) have imposed three new sanctions on Russia:
o Effective August 26, 2019, U.S. banks (as defined below) are...more
8/14/2019
/ Biological-Weapons ,
CBW Act ,
Defense Sector ,
Economic Sanctions ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Exports ,
Foreign Financial Institutions (FFI) ,
National Security ,
NDAA ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sovereign Debt ,
Trump Administration
In a June 4 announcement, the Trump administration further ratcheted up U.S. sanctions and export controls against Cuba by prohibiting group “people-to-people” travel to Cuba and the use of noncommercial aircraft and...more
6/6/2019
/ Aircraft ,
Airline Passengers ,
Bureau of Industry and Security (BIS) ,
Cuba ,
Export Administration Regulations (EAR) ,
Federal Aviation Administration (FAA) ,
Foreign Relations ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Sanctions ,
Trump Administration ,
Vessels
• OFAC recently added a Moscow-based Russian-Venezuelan joint venture bank, Evrofinance Mosnarbank (“Evrofinance”), to the List of Specially Designated Nationals and Blocked Persons (the “SDN List”) for engaging in sanctions...more
3/29/2019
/ Banking Sector ,
Blocked Person ,
Economic Sanctions ,
Financial Institutions ,
Foreign Policy ,
General Licenses ,
Joint Venture ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Russia ,
SDN List ,
Trump Administration ,
Venezuela
• On January 28, 2019, OFAC added the Venezuelan state-owned oil and natural gas company PdVSA to its SDN List.
• As a result, U.S. persons are generally prohibited from engaging in transactions with PdVSA and entities that...more
2/6/2019
/ Blocked Person ,
Bonds ,
Capital Markets ,
Debt-Equity ,
Economic Sanctions ,
Energy Sector ,
Executive Orders ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
SDN List ,
Securities Transactions ,
State-Owned Enterprises ,
Trump Administration ,
Venezuela
• On November 27, 2018, the Trump administration issued an executive order establishing a new sanctions regime against Nicaragua.
• This occurs as the Trump Administration has articulated an approach to Latin America in...more
In this episode, Akin Gump cross-border transactions partner Melissa Schwartz discusses economic sanctions and their impact on transactions, specifically, how businesses minimize the risk they face of sanctions...more
10/18/2018
/ Business Entities ,
CAATSA ,
Cross-Border Transactions ,
Due Diligence ,
Economic Sanctions ,
Foreign Entities ,
Foreign Policy ,
Franchises ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
Risk Assessment ,
Risk Mitigation ,
SDN List ,
Secondary Sanctions ,
Trade Policy ,
Trump Administration
• On September 20, 2018, for the first time, the Trump administration imposed sanctions on a non-U.S. entity and its director for engaging in “significant transactions” with a Russian defense sector company included on the...more
9/26/2018
/ Blocked Person ,
CAATSA ,
Defense Sector ,
Economic Sanctions ,
Executive Orders ,
Intelligence Services ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Secondary Sanctions ,
Suppliers ,
Trump Administration
• On May 22, 2018, OFAC issued General License 15, authorizing U.S. persons to engage in specified transactions related to maintenance or wind-down of operations, contracts or other agreements involving GAZ Group or any...more
• On May 1, 2018, OFAC issued General License 13A authorizing the divestment or transfer of certain debt, equity or other holdings issued by EN+ Group, GAZ Group or United Company RUSAL PLC, as well as entities in which such...more
• On April 6, 2018, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) placed seven prominent Russian businessmen, 12 companies, 17 senior Russian government officials, and a state-owned Russian...more
4/9/2018
/ Banking Sector ,
Blocked Person ,
CAATSA ,
Economic Sanctions ,
Executive Orders ,
Financial Institutions ,
General Licenses ,
Government Officials ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
State-Owned Enterprises ,
Trump Administration ,
U.S. Treasury
On January 12, 2018, the U.S. administration took three actions relating to Iran -
• First, President Trump waived again the application of certain nuclear sanctions while making clear that the United States will refuse to...more
• The next significant Countering America’s Adversaries Through Sanctions Act (CAATSA)-related deadline for the Trump administration is January 29, 2018, when it must submit reports to Congress on “oligarchs and parastatal...more
1/22/2018
/ Arctic Drilling ,
CAATSA ,
Defense Sector ,
Economic Sanctions ,
Energy Sector ,
Executive Orders ,
Foreign Financial Institutions (FFI) ,
National Security ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Russia ,
Shale Gas ,
Trump Administration
• On November 9, 2017, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), the U.S. Department of State, and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) took coordinated...more
12/22/2017
/ Bureau of Industry and Security (BIS) ,
Cuba ,
Cuban Assets Control Regulations (CACR) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Exports ,
Financial Transactions ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Presidential Memorandum ,
Private Sector ,
Trump Administration ,
U.S. Commerce Department ,
U.S. Treasury ,
US Department of State
• On October 27, 2017, the U.S. State Department issued guidance identifying 39 entities related to the defense and intelligence sectors of the Government of the Russian Federation and issued related guidance on criteria to...more
10/31/2017
/ Defense Sector ,
Economic Sanctions ,
Export-Import Bank of the US ,
Exports ,
Extraterritoriality Rules ,
Financial Institutions ,
Foreign Exchanges ,
National Intelligence Agencies ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Secretary of the Treasury ,
State-Owned Enterprises ,
Trump Administration ,
US State Departments
On September 29, 2017, OFAC modified Directives 1 and 2 of Executive Order 13662 to reduce the permissible maturity for new debt issued by Russian financial and energy entities designated under these directives, as well as...more
10/5/2017
/ Banking Sector ,
Cybersecurity ,
Debt ,
Economic Sanctions ,
Energy Sector ,
Executive Orders ,
Foreign Financial Institutions (FFI) ,
Foreign Relations ,
Office of Foreign Assets Control (OFAC) ,
Presidential Directives ,
Russia ,
Trump Administration ,
Ukraine
On August 25, 2017, President Trump issued an Executive Order (EO) imposing economic sanctions related to Venezuela. The new measures prohibit U.S. persons from engaging in certain debt-, equity-, and securities-related...more
8/31/2017
/ Agricultural Sector ,
Blocked Person ,
Bonds ,
Citgo ,
Debt-Equity ,
Dividends ,
Economic Sanctions ,
Executive Orders ,
General Licenses ,
Medical Devices ,
Office of Foreign Assets Control (OFAC) ,
Patented Medicines ,
SDN List ,
Securities Transactions ,
Trump Administration ,
Venezuela
On August 2, 2017, President Trump signed into law the Countering America’s Adversaries Through Sanctions Act of 2017 (Pub. Law. No. 115-44, H.R. 3364) (the “Act”), which significantly expands economic sanctions against...more
8/9/2017
/ Anti-Corruption ,
Anti-Terrorism Financing ,
Arms Embargo ,
Congressional Override ,
Cyber Sanctions ,
Economic Sanctions ,
Executive Orders ,
Exports ,
Foreign Financial Institutions (FFI) ,
Foreign Relations ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
North Korea ,
Oil & Gas ,
Pipelines ,
Privatization ,
Russia ,
SDN List ,
SSI List ,
State-Owned Enterprises ,
Syria ,
Trade Restrictions ,
Trump Administration
On June 16, 2017, the Trump administration issued a national security presidential memorandum entitled “Strengthening the Policy of the United States Towards Cuba” (the “Presidential Memorandum”). Related to this...more
6/21/2017
/ Bureau of Industry and Security (BIS) ,
Business Licenses ,
Cuba ,
Department of Transportation (DOT) ,
Economic Sanctions ,
Financial Transactions ,
Internet ,
Obama Administration ,
Office of Foreign Assets Control (OFAC) ,
Presidential Memorandum ,
Tourism ,
Travel Restrictions ,
Trump Administration