News & Analysis as of

Secondary Sanctions SDN List Office of Foreign Assets Control (OFAC)

Troutman Pepper Locke

Financial Transactions Related to Russian Energy Now Prohibited: Expiration of OFAC ‎General License 8L

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On March 12, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) allowed General License (GL) 8L under the Russian Harmful Foreign Activities Sanctions Regulations to expire. As a result, broad OFAC...more

Husch Blackwell LLP

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

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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

Dechert LLP

Russia/Venezuela Sanctions Update: Additional Sanctions Imposed on Rosneft Trading 

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The U.S.Treasury Department’s Office of Foreign Assets Control (“OFAC”) added Rosneft Trading SA (“Rosneft Trading”), a subsidiary of Russian oil major Rosneft Oil Company (“Rosneft”), to the List of Specially Designated...more

Pillsbury - Global Trade & Sanctions Law

U.S. Expands Secondary Sanctions to Iran’s Industrial Sectors

On January 10, 2020, the United States imposed additional sanctions on Iran in the wake of recent tensions between the countries and the continuing broader ‘maximum pressure’ campaign on Iran. ...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

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

Society of Corporate Compliance and Ethics...

US continues trying to enforce ‘secondary sanctions’

Report on Supply Chain Compliance, Volume 2, no. 19 (October 10, 2019) - In a trend that reaches back at least 18 months, the U.S. designated entities for violating sanctions against Iran and Venezuela. In both cases, the...more

Holland & Knight LLP

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

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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

A&O Shearman

Sanctions Risk: Drafting Contracts to Avoid ‘Double Jeopardy’

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In the recent case of Lamesa Investments Ltd v Cynergy Bank Ltd [2019] EWHC 1877 (Comm), the High Court upheld the bank’s attempt to avoid a common banking dilemma: the ‘double jeopardy’ of being contractually liable to make...more

Dechert LLP

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

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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

Holland & Knight LLP

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

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• 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)

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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

Dechert LLP

OFAC Targets Digital Currency Addresses For the First Time

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In a long-anticipated move, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), on November 28, 2018, took direct aim at the illicit use of digital currencies by identifying two digital currency...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

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

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

Akin Gump Strauss Hauer & Feld LLP

Podcast: Sanctions and Transactions

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

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

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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

Dechert LLP

Financial Services Quarterly Report - Second Quarter 2018: Current U.S. Sanctions Against Russia, Venezuela and Iran

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International sanctions are a major compliance challenge for companies worldwide. The regulatory risks associated with economic sanctions, asset-freezing measures and trade embargoes are not new, but they continue to grow in...more

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