The revised policy both clarifies and expands DOJ’s prior disclosure guidance.
On December 13, 2019, the United States Department of Justice (DOJ) revised its policy regarding voluntary self-disclosures (VSDs) of...more
New restrictions prohibit dealings between US persons and the Government of Venezuela.
On August 5, 2019, President Trump issued Executive Order (E.O.) 13884, entitled “Blocking the Property of the Government of...more
BIS designates Huawei Technologies Co., Ltd. and certain of its affiliates to the Entity List, restricting their ability to receive US products, software, and technology.
On May 16, 2019, the US Commerce Department’s...more
5/24/2019
/ Bureau of Industry and Security (BIS) ,
Cybersecurity ,
Economic Sanctions ,
Entity List ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
General Licenses ,
Huawei ,
Telecommunications ,
U.S. Commerce Department
OFAC outlines baseline considerations for evaluating a risk-based sanctions compliance program.
On May 2, 2019, the US Treasury Department’s Office of Foreign Assets Control (OFAC) published A Framework for OFAC Compliance...more
5/9/2019
/ Audits ,
Black & Decker ,
Chief Compliance Officers ,
Compliance ,
Corporate Counsel ,
Corporate Management ,
Economic Sanctions ,
Enforcement Actions ,
Internal Controls ,
Office of Foreign Assets Control (OFAC) ,
Risk Assessment ,
Training
Trump Administration breaks with precedent to allow US plaintiffs to bring “trafficking” suits under Title III of the Helms-Burton Act.
Title III of the Helms-Burton Act (the Cuban Liberty and Democratic Solidarity...more
OFAC adds PdVSA to its sanctions list and simultaneously issues general licenses temporarily allowing certain transactions and activities involving PdVSA.
On January 28, the US Treasury Department’s Office of Foreign...more
OFAC added several parties to the SDN List and simultaneously issued a General License, authorizing certain wind-down activities until January 8, 2020.
Today, the Treasury Department’s Office of Foreign Assets Control...more
Withdrawal from the Iran nuclear agreement triggers full implementation of US sanctions, including threat of “secondary” sanctions on non-US persons dealing with Iran.
As reported in the Latham Client Alert dated May 10,...more
11/6/2018
/ Economic Sanctions ,
EU ,
Financial Institutions ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
General Licenses ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Secondary Sanctions ,
Trump Administration
In light of the EU’s recent amendments to its long-standing blocking measure, EU operators will need to weigh the consequences of failing to comply with their contradicting obligations under US and EU law.
How has the EU...more
Withdrawal from the JCPOA will lead to re-imposition of several categories of US sanctions.
On May 8, 2018, President Trump announced that the United States will withdraw from the Joint Comprehensive Plan of Action...more
The new designations of Russian individuals and entities broadly expand the scope and impact of sanctions.
Background -
On April 6, 2018, the US Treasury Department’s Office of Foreign Assets Control (OFAC) added more...more
4/13/2018
/ Blocked Person ,
CAATSA ,
Economic Sanctions ,
Executive Orders ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Secondary Sanctions ,
Trump Administration ,
U.S. Treasury ,
Ukraine
The new designations of Russian individuals and entities broadly expand the scope and impact of sanctions.
Background -
On April 6, 2018, the US Treasury Department’s Office of Foreign Assets Control (OFAC) added more...more
4/10/2018
/ 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
Treasury Department Report identifies 114 senior political figures and 96 oligarchs, and confirms that the Report is not a sanctions list -
On January 29, 2018, the Treasury Department submitted a report to the US Congress...more
Treasury Department Report identifies 114 senior political figures and 96 oligarchs, and confirms that the Report is not a sanctions list -
On January 29, 2018, the Treasury Department submitted a report to the US...more
President Trump signs the “Countering America’s Adversaries Through Sanctions Act,” which — among other measures — requires Congressional review to ease Russia-related sanctions.
On Wednesday, August 2, 2017, President...more
9/16/2017
/ Asset Freeze ,
Congressional Authority ,
Cybersecurity ,
Economic Sanctions ,
Foreign Relations ,
Human Rights ,
Iran ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Pipelines ,
Russia ,
SDN List ,
Secondary Sanctions ,
Terrorism Funding ,
Trump Administration
President Trump issues an Executive Order prohibiting certain transactions involving the Venezuelan government and state-owned or state-controlled entities.
Key Points:
..The Executive Order imposes new sanctions that...more
President Trump signs the “Countering America’s Adversaries Through Sanctions Act,” which — among other measures — requires Congressional review to ease Russia-related sanctions.
On Wednesday, August 2, 2017, President...more
President Trump signs the “Countering America’s Adversaries Through Sanctions Act,” which — among other measures — requires Congressional review to ease Russia-related sanctions.
On Wednesday, August 2, 2017, President...more
Trump administration expected to maintain changes, but certain restrictions remain.
In the final days of his administration, President Obama announced significant changes to the US embargo against Sudan, in place since...more
The Guidance parallels the DOJ approach under the FCPA, but does not specify the value of mitigation and may create contradictory incentives.
The National Security Division (NSD) of the US Department of Justice (DOJ)...more
Various factors continue to shape and limit trade and investment between Iran and the rest of the world.
Six months have passed since the implementation of the nuclear agreement with Iran, officially known as the Joint...more
Privy Council clarifies the nature of arbitration clauses, but uncertainties about the clauses’ effect still remain.
“Non-exclusive” arbitration clauses provide that disputes “may” be referred to arbitration (rather than...more
7/14/2016
/ Arbitration Agreements ,
Arbitration Awards ,
Arbitrators ,
Bilateral Investment Treaties ,
Canada ,
Conflicts of Interest ,
Enforceability ,
EU ,
Financial Institutions ,
Forum Selection ,
Free Trade Agreements ,
ICSID ,
Implementation Day ,
International Arbitration ,
International Chamber of Commerce (ICC) ,
Investor State Dispute Settlement (ISDS) ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Restitution ,
Romania ,
SDN List ,
Sovereign Immunity ,
SWIFT ,
Switzerland ,
Venezuela ,
Zimbabwe
The EU and UN terminate most of their sanctions on Iran, while the US implements more limited changes to its longstanding embargo.
On January 16, 2016, the International Atomic Energy Agency (IAEA) verified that Iran...more
Most business executives and officers lack the training and preparation to deal effectively with a search warrant.
State and federal law enforcement agencies continue to increase their investigation and prosecution of...more
Recent and upcoming milestones fuel expectations of Iran opportunities in 2016.
As reported in our Client Alert dated July 16, 2015, the Joint Comprehensive Plan of Action (JCPOA) provides for the eventual termination of...more