On June 12, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced new measures targeting Russia’s financial infrastructure, including:
1. Expanding the scope of financial sanctions:...more
Effective April 24, the statute of limitations (“SoL”) under the International Emergency Economic Powers Act (“IEEPA”) and the Trading with the Enemy Act (“TWEA”) has been extended from five to ten years. It would have been...more
The EU is going extraterritorial, and it is doing so through private contract. It is a pretty neat trick.
As a general rule, EU regulations do not apply extraterritorially. This policy is a bit pointed, intended to stand...more
3/28/2024
/ Asset Freeze ,
Buyers ,
EU ,
European Commission ,
Exporters ,
Exports ,
Extraterritoriality Rules ,
Importers ,
Imports ,
Member State ,
Russia ,
Sanctions ,
SDN List ,
Ukraine
On January 5, 2023, President Biden signed into law S. 1294, the “Protecting American Intellectual Property Act of 2022”. The Act requires the president to report to Congress and impose sanctions on any foreign person or...more
1/19/2023
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
CAATSA ,
China ,
Entity List ,
Export Controls ,
Foreign Entities ,
Foreign Persons ,
Intellectual Property Protection ,
National Security ,
New Legislation ,
Sanctions ,
Theft ,
Trade Secrets ,
Trade Wars
Key Takeaways Background Since October 7, 2022, when the Bureau of Industry and Security (“BIS”) dropped 140 pages of regulations on the semiconductor industry, U.S. passport and green card holders working at Chinese chip...more
On July 7, 2022, the Treasury Department laid out how it would work with its overseas counterparts and in international forums as the U.S. studies cryptocurrencies to set up a possible regulatory regime. This framework is the...more
U.S. Comprehensive Sanctions Against the DNR and the LNR -
Scope: the DNR and LNR -
The new EO does not detail which parts of the Donetsk and Luhansk regions[1] are subject to the new U.S. sanctions. It is likely that...more
2/22/2022
/ Biden Administration ,
EU ,
Executive Orders ,
Export Administration Regulations (EAR) ,
International Trade ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanctions ,
UK ,
Ukraine ,
United States ,
Vladimir Putin
With Russian forces massing at the Ukrainian border, the U.S. and EU have been warning of severe economic sanctions. While we wait and watch this brinksmanship play out, it is worth considering how businesses, and...more
12/16/2021
/ Banks ,
Economic Sanctions ,
EU ,
Financial Institutions ,
Joe Biden ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanctions ,
SWIFT ,
U.S. Treasury ,
Vladimir Putin
If your company is like many, your board of directors may be demanding that you put more effort into environmental, social, and governance issues, which have become known by the now-ubiquitous acronym “ESG.” Those demands...more
10/11/2021
/ Board of Directors ,
Customs ,
Customs and Border Protection ,
Environmental Social & Governance (ESG) ,
Ethical Standards ,
Exports ,
Forced Labor ,
Imports ,
International Trade ,
Sanctions ,
Supply Chain ,
Trade Policy
On June 10, 2021, China enacted the Anti-Foreign Sanctions Law (“AFSL”), aimed at punishing countries that impose anti-China sanctions and the companies that comply with those sanctions. The law is effective immediately, and...more
On February 1, 2021, the Myanmar military overthrew the country’s democratically elected government and installed an army general as head of state, with a cadre of military officials and their allies running the government. ...more
Since the U.S. Government determined that Russia interfered in the 2016 election, movement around Russia sanctions policy has been vigorous, if not unidirectional. In 2016, the United States implemented twice sanctions...more
2/9/2018
/ CAATSA ,
Defense Sector ,
Financial Institutions ,
Foreign Policy ,
Foreign Relations ,
National Security ,
Privatization ,
Russia ,
Sanctions ,
Secondary Sanctions ,
US Department of State
On July 27, 2017, the U.S. Congress sent to President Trump’s desk a bill that imposes new financial sanctions against Russia, Iran, and North Korea. It appears nearly certain that the president will sign that bill, now...more
8/2/2017
/ Energy Sector ,
EU ,
Foreign Relations ,
Mineral Exploration ,
Oil & Gas ,
Pending Legislation ,
Pipelines ,
Resource Extraction ,
Russia ,
Sanctions ,
Trump Administration
Sheppard Mullin’s EU team has created a list of major legal shifts that await General Counsel and Compliance Officers in the areas of competition, EU regulatory and trade in 2017. These challenges may have an impact on your...more
1/25/2017
/ Cartels ,
Competition ,
Data Protection ,
Digital Single Market ,
EU ,
European Commission ,
FRAND ,
General Data Protection Regulation (GDPR) ,
Innovation ,
Merger Controls ,
Popular ,
Sanctions ,
Standard Essential Patents ,
State Aid ,
Trade Agreements ,
UK Brexit
After weeks of negotiations and a Putin-backed delay, the UN Security Council unanimously adopted resolution 2270 on March 2, 2016, imposing new sanctions against North Korea. According to U.S. Secretary of State John Kerry,...more
3/4/2016
/ Arms Embargo ,
Asset Freeze ,
Corporate Counsel ,
Exports ,
Imports ,
North Korea ,
Nuclear Weapons ,
Office of Foreign Assets Control (OFAC) ,
Sanctions ,
SDN List ,
UN Security Council ,
Vessels ,
WMD
On August 30, 2015, the Washington Post broke a story that the Obama administration is developing a package of economic sanctions that will target Chinese companies and individuals who have benefitted from cybertheft. The new...more
9/18/2015
/ China ,
Compliance ,
Cyber Attacks ,
Cyber Crimes ,
Cyber Espionage ,
Cybertheft ,
Data Breach ,
Foreign Corporations ,
Hackers ,
National Security Agency (NSA) ,
Nuclear Power ,
Obama Administration ,
Sanctions ,
Search Engines ,
Source Code ,
Visas
On March 12, 2015, Commerzbank AG, Germany’s second largest bank and a global financial institution, agreed to pay $1.45 Billion (yes, with a “B”) in forfeitures and fines to the U.S. Government for violating U.S. sanctions...more
I will start by saying I am a proud Francophile. I love many things about French culture; from the just-right draw of their espresso (sorry, Italy, that ristretto is just too short and bitter) to the sacrosanct treatment of...more