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In this weekly update, we summarise the most notable updates in the UK sanctions world. ...more
On February 23, building mainly upon the broad authority of Executive Order 14024 (“EO 14024”)[1] issued by President Joe Biden in 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), the...more
In this weekly update, we summarise the most notable updates in the UK sanctions world. If you have any questions in respect of any of the developments set out below, please do not hesitate to contact a member of our London...more
Emigrant Bank (“Emigrant”), a U.S.-based financial institution that bills itself as the oldest bank in New York City, is the latest sanctions violator to be swept up in OFAC’s ongoing enforcement push. On September 21, OFAC...more
The past few weeks have not been kind to 3M. The company recently settled with the SEC for $6.5 million to resolve alleged FCPA violations related to its Chinese subsidiary’s dealings with Chinese state-owned healthcare...more
The Justice Department has touted the upcoming wave of corporate prosecutions for criminal sanctions violation as the era of “The New FCPA.” DOJ’s reference is intended to communicate a strong message – companies are going to...more
Construction Specialties, Inc. (“CSI”), a U.S. company specializing in the sale of building materials, agreed to pay $660,594 to settle its liability for three violations of OFAC’s sanctions on Iran. CSI’s illegal conduct...more
In a relatively rare move for four (4) Cabinet-level Departments, the U.S. Departments of Commerce, Justice, State and Treasury issued an advisory notice on June 9, 2023, aimed specifically at reminding industry of their...more
In this post, we describe the economic sanctions imposed by Canada since our March 28, 2023 update, including additional designations of Russian, Belarusian, Iranian and Haitian persons under existing sanctions regimes and a...more
Over an eight-year period ending in 2018, Murad, a U.S. cosmetics company, illegally exported goods and services to Iran in 62 separate transactions worth approximately $11 million. Murad was acquired by Unilever United...more
The U.S Treasury Department’s Office of Foreign Assets Control (OFAC) recently announced settlements with a California-based cosmetics company and a former senior company executive to resolve potential civil liability...more
On April 27, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions, pursuant to Executive Order 14078, against four senior officials of Iran’s Islamic Revolutionary Guard Corps...more
On February 27, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule (the “Iran Final Rule”) imposing new export control measures against Iran caused by to its support of Russian...more
In this post, we describe the economic sanctions imposed by Canada since our November 5, 2022 update, as well as Russian asset freezing order and a judicial decision in the sanctions law area. We expect more sanctions and...more
On March 21, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions in coordination with the FBI against four entities and three individuals in Iran and Turkey accused of supporting Iran’s...more
On March 9, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions against a China-based network of five companies and one individual accused of supporting Iran’s unmanned aerial vehicle...more
On March 8, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions, pursuant to Executive Orders 13553 and 13846, against several Iranian regime officials and entities for serious human...more
Broadening its response to Russia’s one-year-old assault on Ukraine, the United States announced additional export control and sanctions measures, effective February 24, 2023. These new measures expand restrictions on...more
In this post we describe the sanctions recently imposed by Canada on Iranian individuals and entities following the detention and, according to the Canadian government, apparent killing of Mahsa Amini, an Iranian woman, in...more
With the war in Ukraine raging on, the U.S. continued to escalate its sanctions response against Russia. The U.S. announced extensive trade and investment bans that prohibit U.S. persons from making any “new investment” in...more
The world’s response to Russia’s invasion of Ukraine dominated the first quarter of 2022, as the US and its international partners coordinated efforts to impose unprecedented sanctions designed to isolate the Russian...more
The European Union Blocking Statute was originally adopted in 1996 to counteract US sanctions on Cuba, Iran and Libya, but following a memorandum of understanding entered into between the EU and the US, it has seldom been...more
OFAC is off to a quick start in 2022. After announcing its Airbnb enforcement action in the beginning of January, OFAC announced a settlement with Sojitz (Hong Kong) Limited, a Hong Kong, China-based company that engages in...more
The Court of Justice of the EU has interpreted for the first time the Blocking Regulation. The ruling confirms that it is possible to terminate contracts with a US designated person without providing reasons. However, in...more