News & Analysis as of

SDN List

Sanctions Updates: Cuba, North Korea, Russia, Sudan, Venezuela

by Michael Volkov on

Sanctions compliance is challenging because of the changing nature of sanctions regulations and individuals identified as Specially Designated Nationals. With each new administration, foreign policy priorities are usually...more

U.S. Sanctions Developments in the Trump Administration

by BakerHostetler on

The Trump Administration has been active on the sanctions front as a means of asserting United States foreign policy and national security interests. Congress has also taken an increasingly active and direct role of late,...more

Making the Case for Requiring Beneficial Ownership Information

by Michael Volkov on

In this era of aggressive enforcement, global companies have to integrate beneficial ownership requirements when conducting due diligence of business associates and when engaging customers....more

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

Sudan Now Open For Business, But Risks Remain

On October 12, 2017, the United States made permanent its lifting of a longtime general embargo on trade and investment with Sudan. As a result, U.S. individuals and companies are now generally free to engage in transactions...more

Trump Administration Sets Approach to Implementation of New Russia Sanctions

In recent weeks, the U.S. government has taken a number of significant steps to implement sanctions on Russia under the Countering America’s Adversaries Through Sanctions Act (CAATSA), which President Donald Trump signed into...more

Venezuela Restructuring: A Long Road Ahead?

by Latham & Watkins LLP on

Venezuela’s initiative is unlikely to set the stage for a restructuring of international obligations in the face of US sanctions. Key Points: - US sanctions will prohibit US persons from engaging in a restructuring of...more

Russia Sanctions under CAATSA – U.S. Updates Rules and Provides Guidance on Enforcement

This week, the U.S. government took several steps to implement sections of the Countering America’s Adversaries Through Sanctions Act of 2017 (CAATSA), with implications for Russia-related sanctions and their enforcement. On...more

State Department Identifies Parties Operating in Defense and Intelligence Sectors of Russian Federation

by White & Case LLP on

On October 27, 2017, the US Department of State issued public guidance on the implementation of Section 231 of the Countering America’s Adversaries Through Sanctions Act of 2017 (CAATSA). CAATSA requires the imposition of...more

Iran: Following President Trump’s “Decertification,” New U.S. Sanctions on Iranian Entities and All Eyes on the U.S. Congress

• Effective October 13, 2017, President Trump declined to provide certification that the JCPOA is in the United States’ national interest. Following this “decertification,” the U.S. Congress has 60 days in which to introduce...more

Iran Speech Shifts Pressure to Congress, But Changes Little for U.S. Businesses

by Baker Donelson on

President Trump’s October 13 speech denounced Iran’s “fanatical regime” as a “menace,” and threatened to terminate the 2015 Iran nuclear deal negotiated by Barack Obama and formally known as the Joint Comprehensive Plan of...more

Federal Criminal Case Raises Provocative Questions on US Jurisdiction

by Morgan Lewis on

Can the US government criminally prosecute non-US persons for activities that constitute secondary Iranian sanctions violations with no alleged nexus to the United States?...more

House Passes Bills Targeting Iran’s Missile Program and Hizballah

On October 25, 2017, the U.S. House of Representatives passed three bills and a resolution in response to Iran’s ballistic missile program and threats posed by Hizballah. Notably, neither the bills nor the resolution would...more

Another Market Opens: U.S. Revokes Sudanese Sanctions Program Though Important Limitations Remain in Place

Effective October 12, 2017, the Sudanese Sanctions Regulations (SSR) have been revoked in recognition of the Government of Sudan’s (GOS) sustained positive actions in stopping conflict and improving humanitarian access in...more

Iran Nuclear Deal “Decertified” Although Impact Is Uncertain

by K&L Gates LLP on

On October 13, 2017, President Trump announced that he was “decertifying” Iran’s compliance with the Joint Comprehensive Plan of Action (“JCPOA”), the multi-nation agreement on Iran’s nuclear program that was implemented in...more

OFAC extends sanctions relief for Belarussian conglomerates

by Kelley Drye & Warren LLP on

Today the Office Foreign Assets Control (OFAC) extended sanctions relief for nine Belarussian conglomerates, including Belneftekhim. OFAC has authorized transactions with the listed Belarussian Specially Designated Nationals...more

US Persons and Financial Institutions: Beware when engaging financially with Venezuela

by Foodman CPAs & Advisors on

On 8/25/17, President Donald Trump signed an Executive Order (EO) restricting and prohibiting certain transactions between US Persons and Venezuela. The transactions that are prohibited by US Persons apply wherever a US...more

Despite Revocation of Sudanese Sanctions, Considerations Remain for Those Dealing With Sudan (IRB No. 568)

by Bryan Cave on

Effective October 12, 2017, the U.S. Government has revoked its sanctions against Sudan that were established in Executive Orders 13067 and 13412 and removed a number of Sudanese entities from the SDN List. The revocation...more

U.S. Lifts Sudan Sanctions

by Fox Rothschild LLP on

On October 12, 2017, the United States lifted its general commercial embargo on Sudan. Because Sudan has played a role in international terrorism, the U.S. has maintained a comprehensive embargo against Sudan since 1997....more

Trump Administration Lifts U.S. Sanctions on Sudan; Important Limitations Remain

Based on certain State Department findings, effective October 12, 2017, long-standing U.S. sanctions on the Republic of Sudan administered by OFAC under the Sudan Sanctions Regulations will be terminated, and U.S. persons...more

Not out of the woods yet: What the lifting of Sudan sanctions means for businesses and non-profits

by Hogan Lovells on

Yesterday, on October 12, 2017, the U.S. permanently revoked most sanctions against Sudan. This lifting represents the completion of a process that began in January 2017, and was extended in July 2017. ...more

US lifts most sanctions on Sudan—but key controls and heightened concerns remain

by Dentons on

On October 12, 2017, the United States lifted its general commercial embargo on Sudan, removing sanctions that had prohibited US Persons from engaging in or facilitating most transactions involving Sudan or its government....more

Today, President Trump Decertified the Iran Deal and Announced Tougher Sanctions on Iran

What does decertification mean? For the time being, decertification is a solely U.S. issue. Under the Iran nuclear agreement (known as the Joint Comprehensive Plan of Action, or JCPOA), Iran agreed to limits on its nuclear...more

Comply With the U.S. Treasury’s OFAC Regulations and Avoid Possible Enforcement Action

by Butler Snow LLP on

For a variety of reasons, the United States government prohibits foreign and domestic individuals, groups, companies and other entities from enjoying the benefits of participating in the U.S. economy. ...more

New Sanctions Against North Korea Issued by the United States

by Shipman & Goodwin LLP on

In light of continuous and escalating tensions between North Korea and the United States, companies should be aware of new sanctions against North Korea issued by the United States. On September 20, 2017, the White House...more

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Cybersecurity

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