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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
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 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
As we approach year’s end, and the pace of legislative activity ramps up, it remains critical to keep a close eye on the sanctions-related bills currently making their way, at varying speeds, through the U.S. legislative...more
Over the past few weeks, we have been speculating on the international trends and tides we expect to see in the next four years under a new U.S. presidential administration. So that you can enjoy our prognostications (before...more
Doubling down on an America First foreign policy, a second term for President Trump would focus on continued unwinding post 9/11 military involvement in the Middle East while pursuing normalization of ties between Israel and...more
Earlier this month, France, Germany and the UK triggered the dispute process under the Iran nuclear deal, saying they had been "left with no choice" after Iran decided to further reduce compliance with the agreement. The...more
The Situation: The Trump administration announced a new round of sanctions on January 10, 2020, following escalating tensions between the United States and Iran. The Result: The new sanctions complement existing sanctions...more
With new Iran-related sanctions, the U.S. government is making good on threats to give third-country companies a choice – participate in the U.S. market or participate in the Iranian market. ...more
Europe has come up with a nifty plan to help Iran buy and sell stuff outside the reach of U.S. sanctions. The problem is that the plan is a fraud magnet. How do we know? It’s been tried before, and the fraud was epic. The...more
In 2018, the United States continued to expand its sanctions programs and increase enforcement. While President Donald Trump’s decision to re-impose nuclear-related sanctions on Iran has perhaps drawn the most attention, key...more
Closing out 2018, OFAC announced its plan to lift sanctions against United Co. Rusal and others, despite bi-partisan opposition from Congress. Simultaneously, OFAC continued to target Russia’s defense and intelligence sectors...more
On November 5, 2018 the Department of Treasury’s Office of Foreign Asset Control (“OFAC”) completed the process to re-impose the Iran sanctions program. The 180-day wind-down period for termination of the United States’...more
• As of November 5, 2018, the United States concluded the second of two wind-down periods for re-imposition of U.S. sanctions on Iran following the May 8, 2018, announcement that the United States would cease participation in...more
As described in our prior alert, November 5, 2018 marked the full return ("snapback") of U.S. Iran-related sanctions measures lifted or waived pursuant to the Iran nuclear deal (the Joint Comprehensive Plan of Action or...more
On 5 November 2018 the United States re-imposed the remaining nuclear-related secondary sanctions administered by the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) against Iran that previously had...more
On November 5, 2018, applicable wind-down periods for certain transactions with Iran ended and the second and final set of U.S. secondary sanctions that had been lifted pursuant to the Iran nuclear deal – the Joint...more
On May 8, 2018, the United States withdrew from the Joint Comprehensive Plan of Action and reimposed all pre-JCPOA sanctions against Iran... After a prescribed wind-down period, all U.S. sanctions on Iran are now in force....more
Withdrawal from the Iran nuclear agreement triggers full implementation of US sanctions, including threat of “secondary” sanctions on non-US persons dealing with Iran. As reported in the Latham Client Alert dated May 10,...more
On November 5, 2018, OFAC announced a large number of Iran-related sanctions designations and issued guidance on the end of the 180-day wind down period. ...more
In this episode, Akin Gump cross-border transactions partner Melissa Schwartz discusses economic sanctions and their impact on transactions, specifically, how businesses minimize the risk they face of sanctions violations. ...more
ANTICORRUPTION DEVELOPMENTS - $34 Million SEC Settlement for Legg Mason - On August 27, 2018, the Securities and Exchange Commission (SEC) announced that Legg Mason Inc. will pay more than $34 million to settle an...more
The Trump Administration issued a new executive order on August 6, 2018, in order to reimpose the first tranche of the Iran sanctions lifted by the former Joint Comprehensive Plan of Action (“JCPOA”). ...more
This quarter, companies around the globe prepared to exit Iran-related business in the wake of U.S. sanctions snap-back. Meanwhile, OFAC provided a path to relief to designated Russian entities, extending several deadlines...more
In furtherance of President Trump’s 8 May 2018 announcement that the United States would withdraw from the Iran nuclear deal—the Joint Comprehensive Plan of Action (JCPOA)—on 27 June 2018, the U.S. Department of Treasury’s...more