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On December 18, 2023, the European Union (EU) published its 12th package of sanctions targeting Russia via Regulation (EU) 2023/2878 and Regulation (EU) 2023/2875, which amend Regulation (EU) 833/2014 and Regulation (EU)...more
On May 19, 2023, the United States along with other members of the G7 and other allied countries imposed additional sanctions and export controls meant to further restrict Russian economic activity and degrade Russia’s...more
U.S. companies that found their assets caught up in Russia at the start of the Russia/Ukraine conflict may find relief on paper from U.S. courts. But it remains to be seen whether they can recover in practice....more
Key Points - - A court in London has ruled that the London branch of a German bank, which had issued confirmations of letters of credit issued by a Russian bank as security provided by Russian airlines for leases of...more
Through Council Regulation (EU) 2022/328 of February 25, 2022, the European Union introduced new sanctions relating to, among other things, Russian aggression in Ukraine...more
The U.S. Department of the Treasury's Office of Foreign Asset Control (OFAC) recently issued two general licenses related to aviation and maritime safety. OFAC issued Russia-related General License 40C (GL 40C), Civil...more
The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and...more
The following materials contain a high level description of potential insurance claims and other claims that may be available to a foreign owner, lessor or financier of aircraft stranded in Russia...more
The U.S., European Union (EU), United Kingdom (U.K.) and many other countries have imposed similar but not necessarily identical sanctions on Russia. In corporate jet transactions, the sanctions laws of several jurisdictions...more
Key Points - - In a March 30 press release, the US Commerce Department updated its March 18 list of aircraft that have flown into Russia in apparent violation of Export Administration Regulations by adding 73 aircraft and...more
This alert summarizes the current state of trade measures and restrictions against both Russia and Belarus, following our last update on February 25, 2022....more
In the wake of Russia's military invasion of Ukraine, several countries, starting with the 27 member states of the European Union and followed by the United States, Canada, Switzerland and Norway, have implemented...more
Following the events in Ukraine, various measures have been put in place by the EU, the UK and the US that are expected to have a considerable impact on the aviation and aircraft financing industry. Below we give a round-up...more
In the previous articles in our series Engine Leasing, the Fundamentals, BCLP’s global aviation team has discussed the attraction of engine leasing and the key economic drivers. It has discussed the legal risks associated...more
On December 20, 2019, President Trump signed into law the National Defense Authorization Act for Fiscal Year 2020 (“NDAA 2020”), which includes numerous sanctions-related provisions. The law includes the previously introduced...more
Apollo Aviation Group, now Carlyle Aviation Partners, agreed to pay OFAC $210,600 for 12 violations of the Sudanese Sanctions Program. Carlyle acquired Apollo in December 2018, and Carlyle was not involved in the...more
It will hardly come as a surprise to readers that air transportation and the trade in aircraft and parts is inherently international. Thus, participants in these industries have to keep an unblinking eye on the increasingly...more
On November 7, 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced in an Enforcement Information that Apollo Aviation Group, LLC (Apollo), a Florida-based commercial aviation...more
On October 21, 2019, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) imposing new sanctions on Cuba for human rights abuses and for its support of...more
British Bank Standard Chartered agreed on Tuesday “to pay $1.1 billion to settle allegations by the authorities in the United States and Britain that it violated anti-money laundering laws and economic sanctions.” The...more
• 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
ANTICORRUPTION DEVELOPMENTS – U.S. Agencies Decline to Prosecute Teradata for Alleged FCPA Violations – On February 26, 2018, Teradata Corporation, an Ohio-based enterprise software database management company,...more