Compliance Perspectives: Sanctions, Data and Vetting Third Parties
Polsinelli Podcast - An International Trade Issue That May Impact Your Business
On August 2, 2024, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued Russia-related General License ("GL") 99A, which authorizes through October 12, 2024, the wind-down of transactions...more
ACI’s highly anticipated Proficiency Series on Economic Sanctions provides true immersion into Economic Sanctions with the objective of becoming proficient in 4 weeks. Advance your career and professional development by...more
On November 9, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License (“GL”) 76A to clarify that the GL applies to “Public Joint Stock Company Saint Petersburg...more
For financial institutions and businesses that are subject to the oversight of the Office of Foreign Assets Control (OFAC), compliance needs to be a priority in 2023. OFAC is playing an increasingly active role in overseeing...more
As one of its last acts of 2022, Congress aimed to close loopholes in the Anti-Money Laundering Act of 2020 (AMLA) that left it unclear how and how much whistleblowers would be paid. On Dec. 23, 2022, Congress passed the...more
Switzerland implemented the remaining measures of the EU ninth package of sanctions in its Ordinance on Measures Connected with the Situation in Ukraine (the "Ordinance"switz), with effect from 25 January at 18:00 CET. These...more
UPDATE – December 2022 was another busy month for Entity List additions by BIS. Effective Dec. 21, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) further tightened controls on the Wagner...more
Recently, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) has taken additional actions against Russia in response to its continued invasion of Ukraine. Specifically, OFAC: ..Issued guidance...more
Over the past few weeks, the Office of Foreign Assets Control (OFAC) of the US Department of the Treasury ramped up sanctions pressure against Russia with the announcement of a new ban on certain services in seaborne Russian...more
On August 16, 2022, the United States Court of Appeals for the D.C. Circuit issued its ruling in Estate of Jeremy Isadore Levine, et al. v. Wells Fargo Bank, N.A., No. 21-7036, –F.4th– (D.C. Circuit August 16, 2022), a case...more
Over the past few weeks, the US Department of Treasury Office of Foreign Assets Control (OFAC) took various actions in response to Russia’s continued invasion in Ukraine: ..updated the Specially Designated Nationals and...more
In their June 2022 report “The cost of complacency: illicit finance and the war in Ukraine”, the House of Commons Foreign Affairs Committee (the “FAC”) condemned the UK Government’s historic lack of commitment to tackling...more
Key Takeaways - ..The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is prohibiting the provision of accounting, trust and corporate formation, and management services to any person in the...more
U.S. contractors with global operations are likely aware of the significant restrictions imposed by the federal government in response to the Russian invasion of Ukraine, in the form of new sanctions, allied trade embargoes,...more
Following a meeting of G7 leaders on May 8, 2022, the United States enacted additional sanctions and export control measures in response to the ongoing conflict in Ukraine. Among the changes: a prohibition on U.S. persons...more
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
Following the invasion of Ukraine by Russia, the UK, EU and US have all responded by announcing significant sanctions in respect of Russia and Belarus. The sanctions landscape has been changing at a fast pace and further...more
Western sanctions against Russia have continued to broaden substantially into new areas of trade, especially in the energy sector. Policymakers in Washington DC, Brussels, London and other allied capitals also continue to...more
Broad U.S. export controls and sanctions recently imposed on Russia, Belarus and specific areas of Ukraine may impact companies with international exposure to these regions, including but not limited to industries such as...more
As part of its expanding sanctions against Russia, the Biden Administration on March 8, 2022, issued Executive Order 14066 (“EO 14066,” see here) to bar imports into the United States of Russian crude oil, petroleum;...more
On March 11, 2022, President Biden signed an Executive Order prohibiting exports of US-origin luxury goods to Russia and Belarus and Russian and Belarusian oligarchs, broadening the US import ban on goods originating in the...more
UK DEVELOPMENTS - Further designations - On 10 March 2022, the UK Government added a further seven oligarchs to its list of sanctions targets, including the owner of Chelsea football club, Roman Abramovich. ...more
In response to the Russian Federation’s invasion of Ukraine in February 2022, the U.S., U.K., and EU have implemented sweeping coordinated economic sanctions and export control restrictions targeting key industries, entities,...more
The United States and the European Union imposed additional sanctions this week in response to the Russian Federation’s invasion of Ukraine and the United States announced its intention to make sanctions enforcement a...more
In our previous alert, we discussed the U.S. implementation of significant sanctions and export controls on Russia which will severely impact business transactions with Russian entities. The U.S. and its allies continue to...more