During the first quarter of 2024, there were significant developments in the U.S. sanctions framework. This report summarizes the key developments and provides links to the relevant sources....more
On October 31, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published Directive 1 under Executive Order 14014 (the “Directive”) that will, effective as of December 15, 2023, prohibit...more
On June 21, pursuant to Executive Order 14014, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions against Burma’s Ministry of Defense and two regime-controlled financial institutions....more
2022 was an unprecedented year for U.S. sanctions and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). While the sweeping new U.S. sanctions imposed against Russia and Belarus in unparalleled...more
On January 31, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 14014 against six individuals and three entities connected to Burma’s military regime. ...more
After months of negotiations, Congress revealed the compromise version of the National Defense Authorization Act for Fiscal Year 2023 (NDAA) on December 6, 2022. The bill, viewed as a “must-pass” piece of legislation because...more
On October 21, 2022, the global Financial Action Task Force (“FATF”) added the nation of Myanmar to its so-called “blacklist” of jurisdictions with “strategic deficiencies” in their legal and regulatory regimes that permit...more
The EU takes a major step to expand sanctions on economically important companies and industrial groups, with twenty-two (22) individuals and four (4) entities now added to restrictive measures. Those designated include...more
This is the fifth post in this year’s series examining important trends in white collar law and investigations. Our previous post discussed trends in State AG enforcement. Up next: SEC Enforcement in 2022: A Look Ahead. ...more
2021 was a year of transition in the United States and for the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). OFAC’s year, while busy, was far different from 2020, as the Biden Administration’s...more
Effective June 1, 2021, the U.S. Department of the Treasury's Office of Foreign Assets Control (“OFAC”) published new Burmese Sanctions Regulations (“BSR”) that implement President Biden’s February 10, 2021, Executive Order...more
U.S., UK and EU authorities continue to expand sanctions targeting the Tatmadaw, Myanmar’s armed forces, following the February 17, 2021, military coup in Myanmar (also known as Burma). Over the past month, the United States...more
Recently, on April 9, 2021, the US Commerce Department’s Bureau of Industry and Security (BIS) adopted new restrictions targeting Burma by applying Export Administration Regulations’(EAR’s) military-intelligence end-use and...more
On March 25, 2021, in its effort to intensify international pressure on Min Aung Hlaing’s military government, the US placed sanctions, pursuant to Executive Order 14014, on two holding companies, Myanma Economic Holdings...more
On 22 March 2021, the European Union ("EU") designated a total of 22 individuals and 4 entities as subject to an asset freeze under the EU sanctions regimes relating to Global Human Rights Sanctions and Myanmar/Burma. ...more
There’s been a non-stop bombardment of recent export amendments involving China and other “countries of concern” within the last six months. The main driver behind these has been the U.S. Government’s concern about the...more
Building on the export controls and sanctions measures already imposed by the U.S. government in February in response to the military coup in Burma, the Bureau of Industry and Security (“BIS”) imposed additional export...more
Following the military coup on 1 February 2021 and subsequent human rights violations, the Foreign, Commonwealth, and Development Office added three Myanmar military officers to the UK Sanctions List on 18 February 2021....more
On February 11, 2021, President Biden issued Executive Order 14014 “Blocking Property with Respect to the Situation in Burma.” As of now, these new sanctions are tailored to target the actors engaged in disrupting the...more
Report on Supply Chain Compliance 3, no. 4 (February 20, 2020) - The United States lifted sanctions[1] on a subsidiary of COSCO Shipping Corporation Ltd., the Chinese shipping giant. Last September, the U.S. Department of...more
OFAC had a big year in 2019 and 2020 looks like a continuation. In the last week, OFAC issued two enforcement actions — Eagle Shipping and Park Strategies....more
With Brexit looming, the UK's autonomous sanctions policy is slowly taking shape. This month saw the publication of regulations setting out the post-Brexit UK sanctions regimes for Iran, Burma and Venezuela, which will come...more
On November 8, 2016, Donald John Trump was elected the 45th President of the United States. Following fiery criticism of the Obama Administration’s sanctions policies, including the Iran deal, the lifting of substantial parts...more
OFAC, acting under the direction of President Obama’s Executive Orders, has lifted the economic and financial sanctions against Burma and Côte D’Ivoire. The revisions open these countries, and their financial markets, to...more
On Friday, October 7, 2016, President Obama delivered on a promise that he had made in September by signing an executive order terminating the economic and financial sanctions program on the country of Burma (Myanmar). The...more