News & Analysis as of

Secondary Sanctions Executive Orders

Husch Blackwell LLP

Executive Order Imposes New Russia Sanctions for Foreign Financial Institutions and Prohibits Additional Russian Imports

Husch Blackwell LLP on

On December 22, 2023, President Biden issued Executive Order 14114, which amended previous Executive Orders in order to authorize the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) to impose additional...more

Morrison & Foerster LLP

U.S. Authorizes Secondary Sanctions on Banks Supporting Russia’s Military-Industrial Base

After two years of aggressive sanctions against Russia for its ongoing war in Ukraine, the United States has broadly expanded those sanctions to threaten foreign financial institutions (FFIs) that support Russia’s...more

Morrison & Foerster LLP

OFAC Issues New FAQs Clarifying Iran Secondary Sanctions

On June 5, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued four new frequently asked questions (“FAQs”) that define key terms used in secondary sanctions added to the Iran sanctions...more

ArentFox Schiff

OFAC’s COVID-19 Response: Existing Exceptions, Filing and Compliance Flexibility, and a Little Loosening on Iran

ArentFox Schiff on

Recognizing that COVID-19 is further straining humanitarian needs in sanctioned countries and complicating compliance with economic sanctions, and perhaps also in response to reports that US sanctions are hindering COVID-19...more

Kelley Drye & Warren LLP

New primary and secondary sanctions on Iranian construction, mining, manufacturing, metals and textile industries

Today the president signed a new Executive Order (E.O.) announcing expanded primary and secondary sanctions on Iran, focused on the construction, mining, manufacturing, and textile industries....more

Jones Day

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

Jones Day on

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

Holland & Knight LLP

Navigating the Recent U.S. Sanctions on COSCO (Dalian) and Other Chinese Companies

Holland & Knight LLP on

The U.S. Office of Foreign Assets Control (OFAC) on Sept. 25, 2019, designated COSCO Shipping Tanker (Dalian) Co. Ltd. (COSCO Dalian), Kunlun Shipping Company Ltd., and certain other entities and individuals as Specially...more

Dechert LLP

U.S. Imposes Blocking Sanctions on Government of Venezuela, Signals Additional Secondary Sanctions

Dechert LLP on

On August 5, 2019, the President signed a new executive order ( “EO 13884”) that imposes blocking sanctions on the Government of Venezuela (“GOV”). EO 13884 does not impose a trade embargo or broadly prohibit transactions...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

Morrison & Foerster LLP

The United States Imposes Additional Secondary Sanctions on Iran as Geopolitical Tensions Flare

With tensions rising in the Persian Gulf, and Iran on the brink of pulling out of portions of the Iran nuclear deal, President Trump issued new Executive Order 13871 last Wednesday, May 8, 2019, imposing sanctions on Iran’s...more

Holland & Knight LLP

Ambassador Bolton Warns of Potential U.S. Secondary Sanctions Against Venezuela - Non-U.S. Entities Transacting with Certain...

Holland & Knight LLP on

• National Security Advisor Ambassador John Bolton issued a statement threatening sanctions against non-U.S. banks for facilitating illegitimate transactions with certain Venezuelan individuals and entities. • This...more

Williams Mullen

U.S. Sanctions Laws: Dangers Ahead For Foreign Companies (Part II)

Williams Mullen on

The following is Part II of this article. Secondary Sanctions – Requirements On Non-U.S. Parties That Have No Contacts With the U.S. OFAC also has adopted sanctions that specifically apply to non-U.S. companies and...more

Skadden, Arps, Slate, Meagher & Flom LLP

Skadden's 2019 Insights: Key Developments in US Sanctions

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

Skadden, Arps, Slate, Meagher & Flom LLP

US Terminates All Remaining Sanctions Relief Under Iran Nuclear Deal

On November 5, 2018, the United States reimposed all remaining nuclear-related sanctions against Iran that it had previously lifted in connection with its implementation of the Joint Comprehensive Plan of Action (JCPOA) in...more

Akin Gump Strauss Hauer & Feld LLP

Trump Administration Sanctions Chinese Entity and its Director in First Imposition of Secondary Sanctions under Section 231 of...

• On September 20, 2018, for the first time, the Trump administration imposed sanctions on a non-U.S. entity and its director for engaging in “significant transactions” with a Russian defense sector company included on the...more

Akin Gump Strauss Hauer & Feld LLP

President Trump Issues New Iran Executive Order and Reimposes First Set of Sanctions Following JCPOA Withdrawal

• On August 6, 2018, following President Trump’s decision to withdraw the United States from the JCPOA, the U.S. government announced the reimposition of sanctions on Iran’s automotive sector, its trade in gold and precious...more

Dechert LLP

Iran Sanctions – U.S. Reimposes Sanctions After JCPOA Withdrawal, First Measures Come Into Effect

Dechert LLP on

As expected, following his May 8, 2018, decision to withdraw the United States from the Joint Comprehensive Plan of Action (“JCPOA”), President Trump signed a new Executive Order (“E.O.”) on August 6, 2018, formally...more

Latham & Watkins LLP

US Treasury Department’s New Designations Under the Russia-Related Sanctions: 3 Key Takeaways (Russian version)

Latham & Watkins LLP on

The new designations of Russian individuals and entities broadly expand the scope and impact of sanctions. Background - On April 6, 2018, the US Treasury Department’s Office of Foreign Assets Control (OFAC) added more...more

Skadden, Arps, Slate, Meagher & Flom LLP

US Imposes New Russia Sanctions Targeting Oligarchs, Senior Government Officials and Entities

On April 6, 2018, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced sanctions against seven Russian oligarchs, 12 companies owned or controlled by these oligarchs, 17 senior Russian government...more

Jones Day

With Tensions Rising, the United States Imposes Additional Sanctions on North Korea

Jones Day on

In Short - The Situation: Over the past several months, North Korea has engaged in several activities, particularly relating to missile and nuclear testing, that violate several United Nations resolutions and that...more

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