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OFAC Imposes First Sanctions for Russian Oil Price Cap Violations

For the first time, on 12 October 2023, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposed sanctions on vessels and their owners for breaching the price cap on seaborne Russian crude oil...more

Between a Rock and a Hard Place: The Sanctions Climate for Foreign Investment in Russia - Part I of II

Russia’s invasion of Ukraine and subsequent revelations of alleged atrocities in territories previously controlled by Russia have had a global impact. Dozens of foreign countries (States) have imposed a wide variety of...more

U.S. Imposes Further Rounds of Sanctions on Russia

As an update to our previous alerts of 24 February, 25 February, and 15 March, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) on 24 March announced an additional round of sanctions on Russia—one...more

U.S. Imposes Additional, "Severe" Sanctions on Russia in Response to Russia's Military Advance into Ukraine

As an update to K&L Gates’ previous alert on 24 February, U.S. President Joe Biden announced sanctions and export controls against Russia that are in addition to those imposed on the 21st and 22nd of February. This escalation...more

U.S. Imposes Initial Sanctions in Response to Russia's Threat to Undermine Ukraine's Sovereignty

This week, the United States imposed new economic sanctions in response to efforts by the Russian Federation to undermine the sovereignty and territorial integrity of Ukraine. As discussed herein, they consist of: (1) an...more

New U.S. Sanctions on the Government of Venezuela

President Trump signed a new Executive Order on August 5, 2019, Executive Order 13884 (“EO 13884”), which blocks (i.e., freezes) all property of the Venezuelan government and its political subdivisions, agencies, and...more

Trump Administration Sanctions Venezuela’s State-Owned Oil Company PdVSA

Overview - In a major expansion of U.S. sanctions against Venezuela, the Department of the Treasury, Office of Foreign Assets Control (“OFAC”), named Petróleos de Venezuela, S.A. (“PdVSA”)—Venezuela’s state-owned oil and...more

OFAC Announces Intent to Remove Sanctions on UC Rusal plc, En+ Group plc, and JSC EuroSibEnergo

On December 19, 2018, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) notified Congress of its intent to remove UC Rusal plc (“Rusal”), the major Russian aluminum producer, and two other...more

United States Ceases Participation in Iran Nuclear Deal and Will Implement Pre-Deal Sanctions Regime – Practical Considerations

On May 8, 2018, President Trump formally announced that the United States would cease participation in the Iran nuclear deal, also called the Joint Comprehensive Plan of Action (“JCPOA”). In accordance with a Presidential...more

Further Implementation of Sanctions Legislation

As reported in our prior alert, the Countering America’s Adversaries Through Sanctions Act (“CAATSA”), which was signed into law on August 2, 2017, materially expanded U.S. sanctions against Russia. Notably, the law requires...more

Iran Nuclear Deal “Decertified” Although Impact Is Uncertain

On October 13, 2017, President Trump announced that he was “decertifying” Iran’s compliance with the Joint Comprehensive Plan of Action (“JCPOA”), the multi-nation agreement on Iran’s nuclear program that was implemented in...more

Obama Administration Announces Relief of Sudan Sanctions Measures

On January 13, 2017, President Barack Obama signed an Executive Order (the “Sudan Executive Order”) that will effectively revoke, after six months (i.e., on July 12, 2017), the U.S. trade embargo against Sudan, provided the...more

OFAC Provides Prospective Guidance on Potential “Snap-Back” of Iran Sanctions

On December 15, 2016, the Office of Foreign Assets Control (“OFAC”) in the Department of the Treasury amended its Frequently Asked Questions guidance document (“FAQs”) regarding the Joint Comprehensive Plan of Action...more

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