Current as of June 29, 2023 - This update discusses the May 19, 2023 and subsequent actions taken by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) in response to the continued aggression of...more
In this post we describe the parts of Bill C-19 that, if passed into law by Parliament, will introduce a property confiscation regime into the Special Economic Measures Act and the Sergei Magnitsky Law....more
In this post we discuss disclosure obligations under Canadian economic sanctions and anti-terrorism laws, including in respect of financial services providers. As discussed below: There are disclosure obligations...more
Now that the United States and its allies have deployed many of their available financial and trade weapons in support of Ukraine against Russia's invasion, what happens next? Perhaps more than any other U.S. sanctions...more
In the latest action to expand sanctions against Russia in response to its invasion of Ukraine, on March 8, 2022, President Biden announced in a televised speech a ban on imports of Russian oil, natural gas, and coal into the...more
Australia's Existing Autonomous Sanctions Regime - Australia's existing autonomous sanctions regime is set out in the Autonomous Sanctions Act 2011 (Cth) ("Act")....more
The Biden Administration has signaled an expanded commitment to longstanding U.S. anti-corruption policies, and recent enforcement actions and policy announcements provide insights into what foreign officials, companies and...more
On 7 December 2020, the EU adopted a global human rights sanctions regime. No individuals have been designated yet. Going forward, this means that companies should ensure that they conduct sanctions screening on all...more
A congressional report released on July 29, 2020, by the Senate’s Permanent Subcommittee on Investigations, exposes how Russian oligarchs looking to evade U.S. sanctions are able to exploit loopholes in the art industry....more
This is the sixth in our start-of-year series examining important trends in white collar law and investigations in the coming year. Our previous entry discussed enforcement by the Massachusetts Attorney General’s Office in...more
Additional Restrictions on Exports to Cuba - On October 15, 2019, the Department of Commerce (DOC) amended the Export Administration Regulation (EAR) to further restrict the export and reexport of items to Cuba. The...more
• OFAC proposes new reporting requirement for rejected transactions • Agency issues guidance on dealing with Iran • Additional parties designated under Magnitsky sanctions program • Careful diligence of...more
Bank Secrecy Act/anti-money laundering (BSA/AML) and sanctions matters continue to be a core focus of regulators, law enforcement agencies, policymakers and Congress, and the story of the Obama and Trump Administrations on...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 15, 2018, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned 17 officials of the Government of Saudi Arabia for their purported role in the killing of journalist Jamal...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
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
Following the use of a nerve agent in Salisbury earlier this year, there were calls for the UK to adopt a British equivalent to the US Global Magnitsky Act, enabling the state to sanction gross human rights violations...more
The EU and UK sanctions regimes have seen significant change during the last few months. Discussions are ongoing regarding the UK's plans for its post-Brexit sanctions policy but uncertainty and division dominates the...more
On December 20, 2017, President Trump issued Executive Order 13818 (the “E.O.”) implementing provisions of the Global Magnitsky Human Rights Accountability Act (“Global Magnitsky Act”) (enacted into law in December 2016),...more
ANTICORRUPTION DEVELOPMENTS – Keppel Offshore Reaches Deal with DOJ and Guilty Plea by Counsel Unsealed – On December 22, 2017, Keppel Offshore & Marine Ltd. (KOM), a Singapore based company that operates shipyards and...more
Headlines from the final months of 2017 included the signing of a new executive order with global anti-corruption implications; new guidance on the Trump Administration’s approach to Russia sanctions under CAATSA; tightening...more
On December 20, 2017, the President issued Executive Order 13818 implementing new sanctions against human rights abusers and persons involved in corruption pursuant to the Global Magnitsky Human Rights Accountability Act...more
On December 21, the U.S. Treasury Department announced the implementation of a new global sanctions regime under the Magnitsky Human Rights Accountability Act (the “Global Magnitsky Act”). President Trump issued an Executive...more