The Situation: In an October 1, 2020, Advisory, the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") warned that companies that make or facilitate ransomware payments to threat actors who are...more
The Situation: Companies are facing increased pressure by U.S. Customs and Border Protection ("CBP") and other federal agencies to demonstrate that goods imported into the United States were produced without the use of forced...more
The Situation: In response to events in Syria and in the face of strong Congressional pressure to act, President Trump introduced sanctions targeting Turkey.
The Result: Although the President indicated that a ceasefire...more
10/25/2019
/ Blocked Person ,
Economic Sanctions ,
EU ,
Executive Orders ,
Foreign Financial Institutions (FFI) ,
General Licenses ,
Human Rights ,
Member State ,
NATO ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Secondary Sanctions ,
Steel Industry ,
Syria ,
Tariffs ,
Trump Administration ,
Turkey
On August 5, 2019, President Trump signed Executive Order 13884 ("E.O. 13884") blocking the property of the Government of Venezuela and authorizing sanctions against a range of additional persons. In connection with E.O....more
Ambiguous, undefined terms create uncertainty and confusion, including whether owned or controlled subsidiaries of U.S. companies outside the United States are subject to this reporting requirement.
On June 21, the...more
Companies in the banking/financial, energy, logistics, and shipping sectors should assess their operations to mitigate sanctions compliance risks.
On Monday, April 22, 2019, the Trump Administration announced that, in the...more
The Situation: On April 17, 2019, the Trump Administration announced additional sanctions targeting the so-called "troika of tyranny" – Venezuela and its key regional allies, Nicaragua and Cuba. These sanctions notably...more
Signed into law in August 2018, the Export Control Reform Act ("ECRA") significantly alters U.S. export policy by placing new emphasis and potential controls on critical technologies essential to the nation's security. As...more
The Situation: The U.S. government historically has lagged behind other countries in providing support to investors in developing and emerging markets.
The Development: The Better Utilization of Investments Leading to...more
The Situation: The U.S. government imposed initial sanctions on Russia under the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991. The sanctions relate to the March 2018 attempted assassination of...more
The Situation: African leaders gathered in Kigali, Rwanda, in March 2018 to sign the draft Agreement Establishing the African Continental Free Trade Area ("CFTA") and other related protocols. Forty-four of the 55 Member...more
5/18/2018
/ Africa ,
AGOA ,
Economic Development ,
EU ,
Foreign Investment ,
Free Trade Agreements ,
Manufacturers ,
OPIC ,
Partnership Agreements ,
Trade Agreements ,
Trade Relations ,
TTIP ,
WTO
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
5/14/2018
/ Economic Sanctions ,
Exporters ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
General Licenses ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
National Security ,
Nuclear Weapons ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Trump Administration ,
TSRA
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
5/10/2018
/ Economic Sanctions ,
EU ,
Export Controls ,
Foreign Policy ,
General Licenses ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Trump Administration
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
4/12/2018
/ Blocked Person ,
CAATSA ,
Economic Sanctions ,
Executive Orders ,
Financial Institutions ,
General Licenses ,
Government Officials ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
State-Owned Enterprises ,
Trump Administration ,
U.S. Treasury
On March 19, 2018, President Trump signed an Executive Order prohibiting U.S. persons and anyone within the United States from engaging in "transactions related to, [the] provision of financing for, and other dealings in ......more
The Situation: In November 2017, Robert Mugabe, the only leader Zimbabwe had known in 37 years, was ousted from power.
The Development: Will this change in leadership usher in a new era of good governance and economic...more
12/8/2017
/ Africa ,
Agricultural Sector ,
Arbitration Awards ,
Bilateral Investment Treaties ,
Dispute Resolution ,
Energy Sector ,
Exports ,
Foreign Investment ,
International Arbitration ,
Office of Foreign Assets Control (OFAC) ,
Transparency ,
World Bank ,
Zimbabwe
The Situation: Regulations implementing tightened U.S. policy towards engagement with Cuba have rolled back a number of Obama-era initiatives and are effective immediately.
The Result: Provisions that encourage Cuban...more
12/1/2017
/ Cuba ,
Cuba Restricted List ,
Cuban Assets Control Regulations (CACR) ,
Export Administration Regulations (EAR) ,
Exports ,
Foreign Policy ,
General Licenses ,
Presidential Memorandum ,
Private Sector ,
Trade Relations ,
Travel Restrictions ,
Trump Administration
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
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
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
10/3/2017
/ Aircraft ,
Blocked Person ,
Economic Sanctions ,
Executive Orders ,
Exports ,
Foreign Financial Accounts ,
Foreign Financial Institutions (FFI) ,
Foreign Relations ,
Imports ,
National Security ,
North Korea ,
Nuclear Weapons ,
SDN List ,
Secondary Sanctions ,
Third Country Entities (TCEs) ,
Trade Restrictions ,
Trump Administration ,
Vessels
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
9/5/2017
/ Bonds ,
Citgo ,
Debt-Equity ,
Dividends ,
Economic Sanctions ,
Executive Orders ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Trump Administration ,
Venezuela
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
8/8/2017
/ Congressional Override ,
Economic Sanctions ,
Energy Sector ,
Exports ,
Financial Services Industry ,
Foreign Relations ,
Imports ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Russia ,
SDN List ,
SSI List ,
State-Owned Enterprises ,
Trump Administration
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
On June 16, 2017, President Trump announced revisions to U.S. policy toward engagement with Cuba and a limited rollback of certain sanctions relief provided by the Obama Administration....more
In response to reports that Iran conducted a ballistic missile test launch in February 2017, a former senior U.S. government official announced—and President Trump later echoed over Twitter—that the United States is...more