The world’s response to Russia’s invasion of Ukraine dominated the first quarter of 2022, as the US and its international partners coordinated efforts to impose unprecedented sanctions designed to isolate the Russian...more
5/4/2022
/ Biden Administration ,
China ,
Cuba ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Foreign Policy ,
Iran ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanctions ,
Securities and Exchange Commission (SEC) ,
Ukraine
Since late February 2022, the United States (U.S.), the European Union (EU) and its member states, the United Kingdom (U.K.), and many others—including Japan, Australia, New Zealand, Taiwan and Canada—have imposed sweeping...more
3/23/2022
/ Biden Administration ,
Canada ,
Economic Sanctions ,
EU ,
Foreign Policy ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
Sanctions ,
UK ,
Ukraine
Over the past week, the United States, the European Union and its member states, the United Kingdom, and several other countries have imposed rounds of sweeping new sanctions on Russia in response to its invasion of Ukraine....more
3/1/2022
/ Biden Administration ,
Canada ,
Economic Sanctions ,
EU ,
Foreign Policy ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
Sanctions ,
UK ,
Ukraine
Closing the year with a renewed focus on the People’s Republic of China, the Biden Administration imposed new export restrictions on US-origin technology to Chinese tech firms to hinder the PRC’s military and security...more
1/24/2022
/ Biden Administration ,
China ,
Cyber Attacks ,
Export Controls ,
Exports ,
Forced Labor ,
Hong Kong ,
Imports ,
New Legislation ,
Office of Foreign Assets Control (OFAC) ,
Ransomware ,
Russia ,
Sanctions ,
Ukraine ,
Virtual Currency
The Biden Administration this quarter announced fewer targeted sanctions, but issued several “whole of government” advisories regarding sanctions risks associated with China-related business dealings, as well as virtual...more
10/29/2021
/ Banking Sector ,
Banks ,
Cryptocurrency ,
Customs ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Exports ,
Financial Institutions ,
Office of Foreign Assets Control (OFAC) ,
Sanctions
This quarter, the U.S. announced new sanctions and trade restrictions on China in response to its perceived intrusions on Hong Kong’s autonomy and reported human rights abuses in Xinjiang. The Trump Administration acted...more
This quarter, the U.S. announced new sanctions and trade restrictions on China in response to its recent encroachments on Hong Kong and its reported mistreatment of ethnic minorities. OFAC continued to target shipping...more
FOURTH QUARTER 2019 -
- Congress closes the year by passing new sanctions against China over human rights concerns, while OFAC clarifies the scope of recent actions against Chinese shipping companies.
- In the wake of...more
1/15/2020
/ AML/CFT ,
China ,
Compliance ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Export Controls ,
Exxon Mobil ,
Human Rights ,
Iran ,
Iran Sanctions ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Sanctions ,
Voluntary Disclosure
This quarter, the U.S. acted pursuant to statute to punish Russia for its alleged role in the chemical weapons attack on Sergei Skipal and targeted a handful of individuals and entities for certain other malign activities....more
10/21/2019
/ AML/CFT ,
Anti-Corruption ,
CAATSA ,
Criminal Conspiracy ,
Economic Sanctions ,
Enforcement Actions ,
Executive Orders ,
Export Controls ,
Exports ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Trump Administration
SECOND QUARTER 2019 –
- US extends sanctions to encompass Iranian metals industries and other targets; Iran announces breach of nuclear accord after EU is unable to offset economic impact of renewed US sanctions.
-...more
In this quarter, OFAC lifted sanctions on Rusal and other companies following divestment by Oleg Deripaska. Meanwhile, as Venezuela descends into economic and political crisis, the US targeted PdVSA and others to hasten...more
5/10/2019
/ Counter-Terrorist ,
Cuba ,
Economic Sanctions ,
Enforcement Actions ,
Foreign Policy ,
Helms-Burton Act ,
Iran ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Trade Relations ,
Trump Administration ,
Venezuela
Closing out 2018, OFAC announced its plan to lift sanctions against United Co. Rusal and others, despite bi-partisan opposition from Congress. Simultaneously, OFAC continued to target Russia’s defense and intelligence sectors...more
1/23/2019
/ Counter-Terrorist ,
Drug Trafficking ,
Economic Sanctions ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
General Licenses ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Magnitsky Act ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Trafficking ,
Trump Administration ,
Venezuela
Russia remained at the forefront this quarter, as the Trump Administration imposed new measures and markets reacted to the threat of additional, “crushing” sanctions from Congress on Russian sovereign debt. Meanwhile, EU...more
10/17/2018
/ CAATSA ,
Chemical Weapons ,
Counter-Terrorist ,
Economic Sanctions ,
Enforcement Actions ,
EU ,
Executive Orders ,
Financial Institutions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Magnitsky Act ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Russia ,
Sovereign Debt ,
Trump Administration ,
UK ,
Venezuela
This quarter, companies around the globe prepared to exit Iran-related business in the wake of U.S. sanctions snap-back. Meanwhile, OFAC provided a path to relief to designated Russian entities, extending several deadlines...more
7/12/2018
/ Counter-Terrorist ,
Drug Trafficking ,
Economic Sanctions ,
Enforcement Actions ,
Foreign Policy ,
General Licenses ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Magnitsky Act ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
South Korea ,
Trump Administration ,
Ukraine ,
Venezuela
President Trump announced today the United States’ withdrawal from the Joint Comprehensive Plan of Action and initiated plans to re-impose nuclear-related sanctions that had been suspended under the terms of the 2015 nuclear...more
This quarter saw the announcement of sweeping new sanctions against Russia’s billionaire class and their corporate holdings, and included the Trump Administration’s first issuance of sanctions against Russia for meddling in...more
4/16/2018
/ CAATSA ,
Counter-Terrorist ,
Criminal Prosecution ,
Drug Trafficking ,
Economic Sanctions ,
General Licenses ,
Iran Sanctions ,
Narcotics ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanction Violations ,
SDN List ,
SSI List ,
Terrorism Funding ,
Trump Administration ,
Ukraine ,
Venezuela
It has now been two years since Iran-related sanctions relief took effect under the Joint Comprehensive Plan of Action. While U.S. persons continue to be generally prohibited from engaging in Iran-related business, the JCPOA...more
Headlines from the final months of 2017 included the signing of a new executive order with global anti-corruption implications; new guidance on the Trump Administration’s approach to Russia sanctions under CAATSA; tightening...more
1/9/2018
/ Counter-Terrorist ,
Cuba ,
Drug Trafficking ,
Economic Sanctions ,
Executive Orders ,
Iran Sanctions ,
Magnitsky Act ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sudan ,
Trump Administration
The third quarter was headlined by the imposition of broad new US legislative sanctions against Russia, Iran, and North Korea. The Trump Administration also acted unilaterally to significantly expand sanctions against both...more
The first six months of the Trump Administration saw several notable developments for US sanctions, with particular implications for Russia and Iran. The Administration also declared a shift in US policy toward Cuba. ...more
7/6/2017
/ Counter-Terrorist ,
Cuba ,
Drug Trafficking ,
Economic Sanctions ,
Enforcement Actions ,
Exxon Mobil ,
Foreign Policy ,
Iran Sanctions ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Proposed Legislation ,
Russia ,
Trump Administration ,
Ukraine
On November 8, 2016, Donald John Trump was elected the 45th President of the United States. Following fiery criticism of the Obama Administration’s sanctions policies, including the Iran deal, the lifting of substantial parts...more
On December 15, 2016, the Office of Foreign Assets Control revised its Frequently Asked Questions guidance that concerns the re-imposition of sanctions in the event of a sanctions snapback under the Joint Comprehensive Plan...more
On June 30, 2016, the New York State Department of Financial Services (“NYSDFS”) adopted a final regulation outlining the attributes of a risk-based transaction monitoring and filtering program that certain New York...more
OFAC amends the Cuban Assets Control Regulations to ease Cuban sanctions in response to President Obama’s policy changes announced on December 17, 2014. These revisions have major implications for the banking and financial...more
4/18/2016
/ Boeing ,
Cuban Assets Control Regulations (CACR) ,
EU ,
General Licenses ,
Iran Sanctions ,
Myanmar ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sudan ,
Syria ,
United Nations
Although US and EU sanctions targeting Iran are not likely to be lifted before early 2016, there are a number of issues which US and EU-based financial institutions should be aware of in preparation for sanctions relief as a...more
9/28/2015
/ Banking Sector ,
EU ,
Financial Institutions ,
Implementation Day ,
International Atomic Energy Agency ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
P5+1 Nations ,
SDN List