On October 18, 2021, the U.S. Treasury Department released a long awaited report on its first of its kind “top to bottom” review of U.S. economic and financial sanctions. The report does not make or recommend any immediate or...more
Key Points
- On December 14, 2020, in response to Turkey’s procurement of the S-400 surface-to-air missile system from Russia in 2019, the Trump administration imposed new sanctions on the Turkish Presidency of Defense...more
- On July 1, the Departments of Commerce, Homeland Security, State, and the Treasury issued a joint advisory on the “Risks and Considerations for Businesses with Supply Chain Exposure to Entities Engaged in Forced Labor and...more
7/10/2020
/ China ,
Economic Sanctions ,
Enforcement Actions ,
Exports ,
Federal Contractors ,
Financial Institutions ,
Forced Labor ,
Human Rights ,
Imports ,
Office of Foreign Assets Control (OFAC) ,
Risk Mitigation ,
Supply Chain
- On May 14, 2020, OFAC, the Department of State and the U.S. Coast Guard jointly released guidance for persons involved in the maritime industry regarding common deceptive shipping practices used to subvert U.S. and United...more
6/4/2020
/ Economic Sanctions ,
Energy Sector ,
Enforcement Actions ,
Exports ,
Imports ,
Iran ,
Maritime Transport ,
Metals ,
New Guidance ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Sanction Violations ,
Shipping ,
Supply Chain ,
Syria ,
Unfair or Deceptive Trade Practices ,
Vessels
The new coronavirus, SARS-CoV-2, and the disease it causes, COVID-19, have created diverse, complex, and immediate challenges for world governments, multinational businesses, and other international institutions and projects....more
3/10/2020
/ Airports ,
Coronavirus/COVID-19 ,
Economic Sanctions ,
Exports ,
Federal Funding ,
Health and Safety ,
Imports ,
Infectious Diseases ,
Manufacturers ,
Medical Supplies ,
Multinationals ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
Public Health ,
Risk Assessment ,
Supply Chain ,
Trade Relations ,
Travel Restrictions ,
Travelers
- On February 18, 2020, OFAC designated Rosneft Trading, S.A. (Rosneft Trading), a subsidiary of Russia-based Open Joint-Stock Company Rosneft Oil Company (Rosneft Oil Company), and its president, Didier Casimiro, on the SDN...more
2/21/2020
/ Blocked Person ,
Crude Oil ,
Economic Sanctions ,
Energy Sector ,
Export Controls ,
Exports ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
SDN List ,
Venezuela
• On December 13, 2019, the Department of Justice (DOJ) revised and re-issued its “Export Controls and Sanctions Policy for Business Organizations” (the “Revised Policy”) to “provide greater clarity for companies faced with a...more
12/20/2019
/ Corporate Counsel ,
Corporate Misconduct ,
Criminal Penalties ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Export Controls ,
Exports ,
Financial Institutions ,
Incentives ,
Non-Prosecution Agreements ,
Office of Foreign Assets Control (OFAC) ,
Sanction Violations ,
Voluntary Disclosure
• On August 8, OFAC issued Findings of Violation to two U.S. companies in relation to administrative subpoenas with follow-up responses deemed by OFAC to be inaccurate or incomplete.
• These recent actions build upon a...more
• The U.S. Department of State and the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) have imposed three new sanctions on Russia:
o Effective August 26, 2019, U.S. banks (as defined below) are...more
8/14/2019
/ Biological-Weapons ,
CBW Act ,
Defense Sector ,
Economic Sanctions ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Exports ,
Foreign Financial Institutions (FFI) ,
National Security ,
NDAA ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sovereign Debt ,
Trump Administration
• As of November 5, 2018, the United States concluded the second of two wind-down periods for re-imposition of U.S. sanctions on Iran following the May 8, 2018, announcement that the United States would cease participation in...more
11/27/2018
/ Aircraft ,
Blocking Statutes ,
Cross-Border Transactions ,
Economic Sanctions ,
EU ,
Exports ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Goods or Services ,
Humanitarian Assistance ,
Imports ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Nuclear Weapons ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Popular ,
SDN List ,
Special Purpose Vehicles ,
SWIFT ,
Trade Policy ,
Trump Administration ,
Vessels
• On May 22, 2018, OFAC issued General License 15, authorizing U.S. persons to engage in specified transactions related to maintenance or wind-down of operations, contracts or other agreements involving GAZ Group or any...more
• The U.S. government has withdrawn from the Iran Nuclear Deal and reverted sanctions to the status quo ante by re-imposing secondary sanctions that restrict non-U.S. persons from engaging in a broad range of business in...more
5/10/2018
/ Controlled Foreign Corporations ,
Economic Sanctions ,
Exports ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Trade Policy ,
Trump Administration
Today, OFAC issued General License 14, authorizing U.S. persons to engage in specified transactions related to maintenance or wind down of operations, contracts or other agreements involving RUSAL until October 23, 2018,...more
• On November 9, 2017, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), the U.S. Department of State, and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) took coordinated...more
12/22/2017
/ Bureau of Industry and Security (BIS) ,
Cuba ,
Cuban Assets Control Regulations (CACR) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Exports ,
Financial Transactions ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Presidential Memorandum ,
Private Sector ,
Trump Administration ,
U.S. Commerce Department ,
U.S. Treasury ,
US Department of State
• On October 27, 2017, the U.S. State Department issued guidance identifying 39 entities related to the defense and intelligence sectors of the Government of the Russian Federation and issued related guidance on criteria to...more
10/31/2017
/ Defense Sector ,
Economic Sanctions ,
Export-Import Bank of the US ,
Exports ,
Extraterritoriality Rules ,
Financial Institutions ,
Foreign Exchanges ,
National Intelligence Agencies ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Secretary of the Treasury ,
State-Owned Enterprises ,
Trump Administration ,
US State Departments
Based on certain State Department findings, effective October 12, 2017, long-standing U.S. sanctions on the Republic of Sudan administered by OFAC under the Sudan Sanctions Regulations will be terminated, and U.S. persons...more
10/13/2017
/ Bureau of Industry and Security (BIS) ,
Commerce Control List ,
Commodities ,
Department of Defense (DOD) ,
Economic Sanctions ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Exports ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Secretary of State ,
Sudan ,
Trade Restrictions ,
Trump Administration ,
TSRA
On September 21, 2017, the White House announced additional sanctions against North Korea, following a new round of sanctions imposed by the United Nations on September 11 and an escalation of U.S. sanctions previously...more
9/26/2017
/ Aircraft ,
Anti-Terrorism Financing ,
Economic Sanctions ,
Executive Orders ,
Exports ,
Foreign Financial Institutions (FFI) ,
Foreign Relations ,
Fund Transfers ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Secretary of State ,
Secretary of the Treasury ,
Trade Restrictions ,
Trump Administration ,
Vessels
On August 2, 2017, President Trump signed into law the Countering America’s Adversaries Through Sanctions Act of 2017 (Pub. Law. No. 115-44, H.R. 3364) (the “Act”), which significantly expands economic sanctions against...more
8/9/2017
/ Anti-Corruption ,
Anti-Terrorism Financing ,
Arms Embargo ,
Congressional Override ,
Cyber Sanctions ,
Economic Sanctions ,
Executive Orders ,
Exports ,
Foreign Financial Institutions (FFI) ,
Foreign Relations ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
North Korea ,
Oil & Gas ,
Pipelines ,
Privatization ,
Russia ,
SDN List ,
SSI List ,
State-Owned Enterprises ,
Syria ,
Trade Restrictions ,
Trump Administration
On December 23, 2016, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a Final Rule amending the Iranian Transactions and Sanctions Regulations, 31 C.F.R. Part 560 (ITSR) to expand the...more
On October 18, 2015, the day on which the Joint Comprehensive Plan of Action (“JCPOA”) became effective (“Adoption Day”), the U.S. Department of State (“State Department”) issued contingent waivers of certain extraterritorial...more
10/21/2015
/ Banking Sector ,
Energy Sector ,
Export Controls ,
Exports ,
IAEA ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
US Department of State ,
Waivers
On August 7, 2015, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published a final rule adding the Yuzhno-Kirinskoye Field, a Russian oil and gas field located in the Sea of Okhotsk, to its Entity...more
On June 8, attorneys for the U.S. Department of Justice (DOJ) joined Dutch aerospace company Fokker Services BV (“Fokker”) in appealing the district court’s rejection of Fokker’s deferred prosecution agreement (DPA) with the...more
6/12/2015
/ Aerospace ,
Aircraft Equipment ,
Appeals ,
Burma ,
Civil Monetary Penalty ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Export Controls ,
Exports ,
Fokker ,
Judicial Authority ,
Sanctions ,
Sudan