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
Third-party petitions seeking to ban the importation of goods made with forced labor may affect global supply chains. Petitions are being filed with U.S. Custom and Border Protection seeking to ban the importation into the...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
Happy new year everyone. The government is shut down, but there has already been a flurry of activity in 2019 on the economic sanctions and embargoes front. Here is a summary of where we stand on various sanctions regimes....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
On July 23, 2018, a variety of U.S. government agencies, namely the Department of State, the Department of the Treasury’s Office of Foreign Assets Control ("OFAC"), and the Department of Homeland Security’s Customs and Border...more
This quarter saw the announcement of sweeping new sanctions against Russia’s billionaire class and their corporate holdings, and included the Trump Administration’s first issuance of sanctions against Russia for meddling in...more
The Office of Foreign Assets Control (OFAC)’s new North Korea Sanctions Regulations become effective today. In addition to making certain technical and conforming changes, the newly updated Part 510 incorporates recent...more
On Friday, February 23, 2018, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) imposed blocking sanctions against one individual, twenty-seven entities and twenty-eight vessels known to have previously...more
In 2017 there were a number of major sanctions developments in the EU and the US, with implications for businesses both in terms of keeping their compliance processes effective, and in terms of what to do if breaches are...more
As we discussed further at length, the U.S. and nations around the world have recently sought to implement and impose harsh economic sanctions programs against North Korea to pressure Pyongyang into ceasing its development...more
The Trump Administration has been active on the sanctions front as a means of asserting United States foreign policy and national security interests. Congress has also taken an increasingly active and direct role of late,...more