This update addresses the full implementation of the price cap policy for crude oil and petroleum products of Russian origin by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). On Feb. 3, OFAC...more
In response to the Russian Federation’s (Russia) egregious and unprovoked invasion of Ukraine that began in February 2022, the U.S. government has deployed a whole-of-government approach in imposing sanctions and export...more
In response to a variety of activities allegedly undertaken by Russia, the U.S. Government has imposed a series of additional sanctions and export control measures since early March. Collectively, the March and April...more
Hong Kong Updates and Alerts - New Restrictions on Exports to Hong Kong – License Exceptions for Hong Kong Suspended - On June 29, 2020, the State Department announced that the U.S. will end the export of U.S.-origin...more
This quarter, the U.S. acted pursuant to statute to punish Russia for its alleged role in the chemical weapons attack on Sergei Skipal and targeted a handful of individuals and entities for certain other malign activities....more
As part of the 18th anniversary of the September 11 attacks earlier this month, the Trump Administration effectively declared the old adage that “one person’s terrorist is another person’s freedom fighter” does not apply with...more
SECOND QUARTER 2019 – - US extends sanctions to encompass Iranian metals industries and other targets; Iran announces breach of nuclear accord after EU is unable to offset economic impact of renewed US sanctions. -...more
Last week, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”), the EU Council, and Canada imposed further sanctions targeting Russian individuals and entities allegedly involved in the escalation of...more
The following is Part II of this article. Secondary Sanctions – Requirements On Non-U.S. Parties That Have No Contacts With the U.S. OFAC also has adopted sanctions that specifically apply to non-U.S. companies and...more
Russia remained at the forefront this quarter, as the Trump Administration imposed new measures and markets reacted to the threat of additional, “crushing” sanctions from Congress on Russian sovereign debt. Meanwhile, EU...more
ANTICORRUPTION DEVELOPMENTS - Petrobras Settles with U.S. Authorities Over Alleged FCPA Violations - On September 27, 2018, the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC)...more
• Economic sanctions and export restrictions extended • Russian investment in United States likely subject to heightened scrutiny • Diligence on Russia transactions and business partners is essential to ensure...more
• On September 20, 2018, for the first time, the Trump administration imposed sanctions on a non-U.S. entity and its director for engaging in “significant transactions” with a Russian defense sector company included on the...more
The past two weeks have entailed a flurry of sanctions developments related to Russia, including the issuance of a new executive order, and the designation of a number of entities by the U.S. Department of the Treasury's...more
ANTICORRUPTION DEVELOPMENTS - SEC Proposes Amendments to Whistleblower Award Program - On June 28, 2018, the Securities and Exchange Commission (SEC) proposed amendments to its whistleblower award process for the first...more
The Trump Administration has been active on the sanctions front as a means of asserting U.S. foreign policy and national security interests. Congress has also taken an increasingly active and direct role of late, beyond its...more
On April 6, 2018, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) added 38 new designees to its list of Specially Designated Nationals and Blocked Persons (“SDN List”) related to Russia pursuant to...more
The new designations of Russian individuals and entities broadly expand the scope and impact of sanctions. Background - On April 6, 2018, the US Treasury Department’s Office of Foreign Assets Control (OFAC) added more...more
On April 6, 2018, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced sanctions against seven Russian oligarchs, 12 companies owned or controlled by these oligarchs, 17 senior Russian government...more
The Situation: The Trump Administration has imposed sanctions against a number of high-profile Russian individuals and entities by adding them to the Specially Designated Nationals and Blocked Persons ("SDN") List. The...more