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As Russia continues its war against Ukraine and Ukraine has itself recently opened a new front by capturing Russian territory in its Kursk region, the United States announced on August 23 its latest tranche of sanctions...more
The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has released a $7.45 million penalty against State Street Bank and Trust Company and its non-bank, fintech subsidiary Charles River Systems for...more
On 24 June 2024, the EU adopted its 14th package of sanctions against Russia. The latest measures include: The designation of 116 additional individuals and entities across a number of industries for their responsibility in...more
The new EU notification requirements relating to transfers of funds out of the EU by EU entities with a certain level of direct or indirect Russian ownership enters into force soon. The reporting obligation has a broad scope,...more
On 11 December 2023, the UK Government announced plans to create the Office of Trade Sanctions Implementation (OTSI), a new governmental body that will be responsible for inter alia the civil enforcement of UK trade...more
Canada, like other major jurisdictions, has a broad range of economic and financial sanctions targeting foreign states and their nationals, as well as various terrorist organizations....more
Fourteen months into the Ukraine war, the Russian Government has introduced new countersanctions targeting foreign investors in Russia. The latest measures require businesses from “unfriendly” countries to make a “voluntary...more
Recent developments, including Russia’s invasion of Ukraine, ongoing tensions between the U.S. and China, and turmoil in the digital assets sector, have made it essential for companies — including their directors and senior...more
The proliferation of U.S. sanctions and other regulations affecting cross-border transactions has implications for directors, who may be personally liable for violations in some cases. Meanwhile, the Securities and Exchange...more
Over the past month, the Government of Canada has implemented wide-ranging economic sanctions and other measures targeting Russia in connection with the conflict in Ukraine. We summarized the initial wave of measures in our...more
On 26 April 2021, the UK’s first sanctions under the Global Anti-Corruption Sanctions Regulations 2021 (SI 2021/488) (“the Regulations”) came into force. The Regulations are made under the Sanctions and Anti-Money Laundering...more
In a precedent-setting agreement, the Justice Department, OFAC and the Bureau of Industry and Security announced a settlement with SAP SE for more than $8 million for numerous violations of the Iran Sanctions program....more
The Situation: On July 10, 2018, the D.C. Circuit held that the Foreign Sovereign Immunities Act's ("FSIA") expropriation exception to sovereign immunity extended to a sovereign's taking of its own nationals' property in an...more
On February 3, 2021, the U.S. Supreme Court issued its anticipated decision in Germany v. Philipp, a case implicating the exception to foreign sovereign immunity for claims arising out of “property taken in violation of...more
Below is a broad overview of policies for which President-Elect Biden has indicated support (PDF). It is important to note that, while some of these policies fall under the President's executive power, many will require...more
OFAC continues to chalk up enforcement actions. For the year, even with the pandemic slow down, OFAC has reached 13 settlement agreements totaling $18.6 million in penalties....more
United States export control, sanctions, and foreign investment (CFIUS) regulations advance U.S. national security and foreign policy interests, but in very different ways. They are also quite complex. As a result, media...more
The Situation: On April 17, 2019, the Trump Administration announced additional sanctions targeting the so-called "troika of tyranny" – Venezuela and its key regional allies, Nicaragua and Cuba. These sanctions notably...more
Congress has agreed upon two pieces of legislation soon to be signed by the President that will provide for a major expansion in the (i) screening by the Committee on Foreign Investment in the United States ("CFIUS") of...more
On December 2, President Obama, acting under the Exon-Florio law, blocked the planned acquisition by China's Fujian Grand Chip Investment Fund LP ("Fujian Grand Chip"), a Chinese investment fund, of the U.S. operations of...more
According to this Reuters article and a blog by Elm Sustainability Partners LLC, an informal deal for EU conflict minerals legislation has been reached. The final text will be voted on by the member states on December 7,...more