News & Analysis as of

Office of Foreign Assets Control (OFAC) Trump Administration Foreign Financial Institutions (FFI)

Morrison & Foerster LLP

OFAC 2020 Year In Review

In too many ways to count, 2020 was an extraordinary year. As we move into 2021 with optimism for an end to the pandemic and better days ahead, we understand that the activity last year of the U.S. Department of the...more

BCLP

Updates on U.S. sanctions affecting parties in Hong Kong and China - December 2020

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Following our recent Client Alert published in October 2020 on the release of the Section 5(a) Report under the Hong Kong Autonomy Act of 2020 (“HKAA”), there have now been some further updates in relation to U.S. sanctions...more

Morgan Lewis

Hong Kong Autonomy Act: An Update

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The US Secretary of the Treasury announced sanctions this summer on 11 individuals who the Secretary views as being involved in implementing the recently enacted Law of the People’s Republic of China on Safeguarding National...more

Morrison & Foerster LLP

Hong Kong In The Crosshairs: Secretary Of State Submits Hong Kong Autonomy Act Report To Congress, Paving Path For Secondary...

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On Wednesday, October 14, 2020, the U.S. Department of State (“State”) submitted a report to the U.S. Congress, as required under section 5(a) of the Hong Kong Autonomy Act (“HKAA”), identifying foreign persons materially...more

Skadden, Arps, Slate, Meagher & Flom LLP

US Responds to Developments in Hong Kong With Sanctions, US Export Control Amendments

In the wake of China’s new national security law for Hong Kong that went into effect on June 30, 2020, the Trump administration has taken several steps to significantly pare back Hong Kong’s preferential status under U.S....more

White & Case LLP

New Sanctions Target Iran’s Metals, Construction, Mining, Manufacturing, and Textiles Industries

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On January 10, 2020, the President signed a new Executive Order (EO), "Imposing Sanctions With Respect to Additional Sectors of Iran," targeting Iran's construction, mining, manufacturing, and textiles industries. On the same...more

Faegre Drinker Biddle & Reath LLP

President Trump Imposes Sanctions on Companies Doing Business with Iran’s Construction, Mining, Manufacturing and Textiles...

On January 10, 2020, President Trump issued a new Executive Order that imposes the latest in a series of economic sanctions on Iran. Individuals and entities violating these and other sanctions on Iran can face significant...more

Hogan Lovells

U.S. government announces enhanced due diligence process for humanitarian trade with Iran and identifies Iran as a jurisdiction of...

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On 25 October the U.S. Departments of the Treasury and State announced the establishment of a new channel for conducting due diligence on humanitarian trade with Iran. Foreign governments and foreign financial institutions...more

Jones Day

U.S. Imposes Sanctions on Turkish Officials, Ministries in Response to Syrian Offensive

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The Situation: In response to events in Syria and in the face of strong Congressional pressure to act, President Trump introduced sanctions targeting Turkey. The Result: Although the President indicated that a ceasefire...more

Skadden, Arps, Slate, Meagher & Flom LLP

US Imposes New Sanctions Targeting Turkish Government Officials and Entities

In light of Turkey’s military intervention in northeast Syria, President Donald Trump issued, on October 14, 2019, Executive Order 13894 (EO 13894), “Blocking Property and Suspending Entry of Certain Persons Contributing to...more

Hogan Lovells

U.S. government issues new executive order targeting Turkey and sanctions the Turkish Ministry of Defense, Ministry of Energy and...

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On 14 October, President Donald Trump issued Executive Order 13894, Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation in Syria (EO). ...more

Akin Gump Strauss Hauer & Feld LLP

Second Round of U.S. Sanctions on Russia Pursuant to the Chemical and Biological Weapons Control Act

• The U.S. Department of State and the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) have imposed three new sanctions on Russia: o Effective August 26, 2019, U.S. banks (as defined below) are...more

Akin Gump Strauss Hauer & Feld LLP

Trump Administration Expands Sanctions Targeting Iran’s Industrial Metals Sector

• President Trump issued a new Executive Order (EO) on May 8, 2019—exactly one year after the Trump administration withdrew from the Iran nuclear deal—that widened the scope of existing sanctions targeting the Iranian...more

White & Case LLP

Iran Threatens Partial JCPOA Suspension; US Imposes Sanctions on Certain Iranian Metals Sectors

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On May 8, 2019, following Iran's announcement that it intends to suspend certain nuclear proliferation-related commitments under the Joint Comprehensive Plan of Action (JCPOA), the United States issued a new Executive order...more

A&O Shearman

Sanctions Round Up: Fourth Quarter 2018

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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

Akin Gump Strauss Hauer & Feld LLP

Iran Sanctions Are Here—Breaking Down What This Means For Business

• 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

Dechert LLP

End of the Road: U.S. Sanctions on Iran Come Back Into Effect

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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

Sheppard Mullin Richter & Hampton LLP

Client Alert: Iran Sanctions Are Back On: Can Business Continue?

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

Latham & Watkins LLP

Top 10 Things to Know About Expanded US Sanctions on Iran

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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

Sheppard Mullin Richter & Hampton LLP

Client Alert: Iran Sanctions Return

1. All sanctions on Iran that were in place before January 2016 will be re-imposed no later than November, 4 2018. 2. Secondary sanctions that penalize non-U.S. persons doing business with Iran will be reinstated. 3....more

Jones Day

Impact of U.S. Withdrawal from the Iran Nuclear Deal

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The Situation: On Tuesday, May 8, 2018, President Trump announced that the United States has withdrawn from the Iran Nuclear Deal and will fully reimpose its suspended sanctions targeting Iran. The Result: All currently...more

Holland & Knight LLP

How Will the United States’ Withdrawal From the Iran Nuclear Accord Affect the Aviation Industry?

Holland & Knight LLP on

On May 8, President Trump announced that the United States is withdrawing from the multilateral nuclear accord with Iran known as the Joint Comprehensive Plan of Action (JCPOA). The U.S. will reimpose sanctions suspended...more

Akin Gump Strauss Hauer & Feld LLP

President Trump Announces U.S. Withdrawal from JCPOA; U.S. Sanctions on Iran will be Re-imposed Following Wind-Down Periods

• The U.S. government has withdrawn from the Iran Nuclear Deal and reverted sanctions to the status quo ante by re-imposing secondary sanctions that restrict non-U.S. persons from engaging in a broad range of business in...more

Akin Gump Strauss Hauer & Feld LLP

Implementing CAATSA Sanctions on Russia: Approaching Deadlines for “Oligarchs” and “Sovereign Debt” Reports and Recap of Latest...

• The next significant Countering America’s Adversaries Through Sanctions Act (CAATSA)-related deadline for the Trump administration is January 29, 2018, when it must submit reports to Congress on “oligarchs and parastatal...more

Pillsbury - Global Trade & Sanctions Law

Evolving U.S. and UN Sanctions Against North Korea

Following President Trump’s trip to Asia, sanctions policies for North Korea continue to evolve. The U.S. government has strengthened sanctions through legislation and Presidential Executive Orders. Further, it is enforcing...more

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