In conjunction with the Group of Seven (G7) leaders meeting in Italy earlier this month, key jurisdictions issued the latest in a series of coordinated economic restrictions on Russia in light of its invasion of Ukraine in...more
7/1/2024
/ Belarus Sanctions ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
EU ,
Export Controls ,
Financial Transactions ,
Foreign Financial Institutions (FFI) ,
Foreign Trade Regulations ,
G7 ,
General Licenses ,
Military Conflict ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Technology ,
UK ,
Ukraine
Medical device companies have a new regulatory pathway for exporting certain U.S.-origin medical products to Russia, Belarus, Crimea and other regions of Ukraine (i.e., the so-called Donetsk People’s Republic and Luhansk...more
5/6/2024
/ Belarus ,
Bureau of Industry and Security (BIS) ,
Crimea ,
Entity List ,
Exceptions ,
Export Controls ,
General Licenses ,
Medical Devices ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Regulatory Requirements ,
Russia ,
TSRA ,
Ukraine
On March 6, 2024, the U.S. Departments of the Treasury, Commerce, and Justice jointly issued a Tri-Seal Compliance Note titled “Obligations of Foreign-Based Persons to Comply with U.S. Sanctions and Export Control Laws”...more
Companies faced with the decision of whether to voluntarily self-report sanctions breaches to law enforcement or sanctions enforcement agencies in the UK and the US can take some measure of comfort from recent comments made...more
10/16/2023
/ Compliance ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Good Faith ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Sanction Violations ,
Self-Reporting ,
Serious Fraud Office (SFO) ,
U.S. Commerce Department ,
U.S. Treasury ,
UK ,
Voluntary Disclosure
On May 19, in response to Russia’s ongoing invasion of Ukraine, the United States, in coordination with allies and partners, announced new sanctions restrictions and export controls targeting Russia’s evasion networks,...more
6/5/2023
/ Asset Freeze ,
Avoidance ,
Banking Sector ,
Biden Administration ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Energy Sector ,
EU ,
Executive Orders ,
Export Controls ,
General Licenses ,
Military Conflict ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
UK ,
Ukraine
The year since Russia’s invasion of Ukraine has been marked by the development of a multi-jurisdictional, multi-agency sanctions regime in the United States, the United Kingdom and the European Union. Although coordination...more
4/28/2023
/ Asset Freeze ,
Asset Recovery ,
Compliance ,
Economic Sanctions ,
Enforcement ,
Enforcement Authority ,
EU ,
G7 ,
Member State ,
Military Conflict ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Regulatory Oversight ,
Russia ,
UK ,
Ukraine
A ban on services related to the maritime transport of Russian-origin crude oil sold above a pre-determined price cap of $60 per barrel began on December 5, 2022, with a similar price cap ban related to other Russian-origin...more
12/7/2022
/ Australia ,
Commodities ,
Economic Sanctions ,
EU ,
Exports ,
G7 ,
Global Market ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Oil Prices ,
Russia ,
Ukraine
The United States, the European Union (EU), the United Kingdom (UK), and other allies and partners are implementing wide-ranging, novel sanctions and sweeping export controls against Russia in response to its invasion of...more
2/28/2022
/ Biden Administration ,
Blocked Entities ,
Blocked Person ,
Economic Sanctions ,
Embargo ,
EU ,
Financial Institutions ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
UK ,
Ukraine
Top EU Court Rules on the EU Blocking Regulation Against US Sanctions for the First Time -
On December 21, 2021, the Court of Justice of the European Union (CJEU), sitting as a “Grand Chamber” (a formation used, among...more
The US Treasury Department has released its 2021 Sanctions Review (the “Review”), which describes the US sanctions framework and the agency’s future sanctions priorities. The Review reflects on the evolution over two decades...more
10/20/2021
/ China ,
Corporate Counsel ,
Economic Sanctions ,
EU ,
Hong Kong ,
Iran ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Public Policy ,
Russia ,
U.S. Treasury ,
Venezuela ,
Virtual Currency
On April 29, 2021, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced two settlements of potential civil liability with two companies over their apparent violations of its regulations. The...more
5/7/2021
/ Bureau of Industry and Security (BIS) ,
Civil Monetary Penalty ,
Compliance ,
Department of Justice (DOJ) ,
Due Diligence ,
Economic Sanctions ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Money Transfer ,
Moneygram ,
Non-Prosecution Agreements ,
Office of Foreign Assets Control (OFAC) ,
Pass-Through Entities ,
SAP SE ,
SDN List ,
Settlement ,
Subsidiaries ,
Third-Party Risk ,
Voluntary Disclosure
On April 15, 2021, President Biden signed a new executive order, Blocking Property with Respect to Specified Harmful Foreign Activities of the Government of the Russian Federation, escalating US sanctions against the Russian...more
On December 28, 2020, the Department of the Treasury Office of Foreign Assets Control (OFAC) published awaited guidance on the implementation of Executive Order (EO) 13959, “Executive Order on Addressing the Threat from...more
The COVID-19 pandemic has had profound economic and political effects over the past several months. Increasingly, those effects have led a number of US policymakers, US allies, and others to question certain US sanctions...more
5/5/2020
/ Coronavirus/COVID-19 ,
Economic Downturn ,
Economic Sanctions ,
Human Rights ,
Importers ,
Imports ,
Iran Sanctions ,
Medical Equipment ,
Office of Foreign Assets Control (OFAC) ,
Personal Protective Equipment ,
Trade Relations ,
U.S. Treasury
On December 13, 2019, the National Security Division (NSD) of the U.S. Department of Justice (DOJ) issued a revised policy regarding voluntary disclosure of export control and sanctions violations by business organizations...more
12/27/2019
/ Amended Regulation ,
Arms Export Control Act ,
Bureau of Industry and Security (BIS) ,
Compliance ,
Cooperation ,
Department of Justice (DOJ) ,
Directorate of Defense Trade Controls (DDTC) ,
Economic Sanctions ,
Enforcement Guidance ,
Export Administration Regulations (EAR) ,
Export Control Reform Act (ECRA) ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
International Emergency Economic Powers Act (IEEPA) ,
ITAR ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Regulatory Standards ,
Voluntary Disclosure ,
Willful Blindness ,
Willful Misconduct
On August 5, 2019, President Donald Trump signed Executive Order 13884, Executive Order Blocking Property of the Government of Venezuela (EO 13884). EO 13884 is designed to further increase pressure on the Nicolás Maduro...more
8/7/2019
/ Blocked Person ,
Citgo ,
Economic Sanctions ,
Executive Orders ,
Financial Institutions ,
Foreign Policy ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Petroleum ,
Trump Administration ,
U.S. Treasury ,
Venezuela
On March 27, 2019, the Office of Foreign Assets Control (OFAC) announced a settlement agreement with US-based Stanley Black & Decker, Inc., (Stanley Black & Decker) and its foreign subsidiary, Jiangsu Guoqiang Tools Co., Ltd....more
4/2/2019
/ Black & Decker ,
Chief Compliance Officers ,
Compliance ,
Corporate Counsel ,
Economic Sanctions ,
Enforcement Actions ,
Exports ,
Foreign Subsidiaries ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
Settlement ,
Subsidiaries
Yesterday, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated Petróleos de Venezuela, S.A. (PdVSA) pursuant to Executive Order 13850, adding the state-owned Venezuelan oil company to its...more
On November 28, the Treasury Department sanctioned two Iran-based individuals for exchanging bitcoin into Iranian rials on behalf of malicious cyber actors involved in the SamSam ransomware scheme. Notably, this action marks...more
12/3/2018
/ Bitcoin ,
Crypto Exchanges ,
Cryptocurrency ,
Digital Currency ,
Economic Sanctions ,
Iran ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
Ransomware ,
SDN List ,
U.S. Treasury
On November 5, 2018, the United States took steps to complete the U.S. withdrawal from the Joint Comprehensive Plan of Action (“JCPOA”), under which the United States – along with its partners in the P5+1 – had previously...more
11/9/2018
/ Blocked Entities ,
Economic Sanctions ,
EU ,
Executive Orders ,
Financial Institutions ,
General Licenses ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
P5+1 Nations ,
SDN List ,
Trump Administration ,
UN Security Council
President Donald Trump issued an Executive Order “Reimposing Certain Sanctions with Respect to Iran” (“New Iran E.O.”) on August 6, 2018, authorizing the re-imposition – or “snap-back” – of various sanctions against dealings...more
On Tuesday, May 8, President Trump announced that the United States would end its participation in the Joint Comprehensive Plan of Action (JCPOA), signed by the Permanent Five Members of the Security Council plus Germany...more
On December 20, 2017, President Trump issued a new Executive Order (EO) targeting corruption and human rights abuses around the world.
The EO implements last year's Global Magnitsky Human Rights Accountability Act (the...more
On November 9, 2017, the US Departments of the Treasury and Commerce implemented President Trump's June 2017 National Security Presidential Memorandum (NSPM) that was designed to tighten restrictions on individual travel to...more
On August 24, 2017, the Trump Administration significantly expanded sanctions against the Government of Venezuela, including state-owned oil company Petroleos de Venezuela, S.A. (PdVSA). These latest sanctions reflect...more