The court explains how the controversial EU law operates to bar EU persons from complying with US sanctions on Iran and Cuba.
On 21 December 2021, the Court of Justice of the European Union (CJEU) released its long-awaited...more
The new rules are set to go in effect when the UK leaves the European Union on 31 December at 11 p.m. GMT.
The United Kingdom’s transition period for withdrawing from the European Union is scheduled to end on 31 December...more
The UK imposes travel bans and financial sanctions on eight Belarusian officials - including Belarus’ President.
On 29 September 2020, the United Kingdom imposed sanctions on eight Belarusian officials it considers to have...more
Supply chain, end use, and human rights–related sanctions, export controls, and Entity List designations target public and private entities in China.
Human rights–related designations -
The US government has...more
The regulations will enable the UK government to sanction persons “involved” in human rights abuses — potentially anywhere in the world.
On 6 July 2020, the UK Foreign Secretary announced the introduction of the Global...more
The penalty reflects the increasingly active approach in the UK to the enforcement of sanctions breaches.
The UK’s financial sanctions regulator, HM Treasury’s Office of Financial Sanctions Implementation (OFSI), has...more
The revised policy both clarifies and expands DOJ’s prior disclosure guidance.
On December 13, 2019, the United States Department of Justice (DOJ) revised its policy regarding voluntary self-disclosures (VSDs) of...more
The number of CFIUS notices filed is growing, more cases are extending into an investigation phase, and instances of pulling and refiling CFIUS notices are increasing.
On November 22, 2019, the Committee on Foreign...more
11/27/2019
/ Acquisitions ,
Annual Reports ,
CFIUS ,
China ,
Critical Infrastructure Sectors ,
Cross-Border Transactions ,
Federal Pilot Programs ,
FIRRMA ,
Foreign Investment ,
Investors ,
National Security
CFIUS has offered a one-month comment period for proposed rulemaking to implement provisions of CFIUS legislation passed in August 2018.
More than a year ago, in August 2018, US President Donald Trump signed the Foreign...more
9/27/2019
/ CFIUS ,
Covered Transactions ,
Critical Infrastructure Sectors ,
Cross-Border Transactions ,
Export Controls ,
Federal Pilot Programs ,
FIRRMA ,
Foreign Investment ,
National Security ,
Real Estate Transactions ,
U.S. Treasury
New restrictions prohibit dealings between US persons and the Government of Venezuela.
On August 5, 2019, President Trump issued Executive Order (E.O.) 13884, entitled “Blocking the Property of the Government of...more
BIS designates Huawei Technologies Co., Ltd. and certain of its affiliates to the Entity List, restricting their ability to receive US products, software, and technology.
On May 16, 2019, the US Commerce Department’s...more
5/24/2019
/ Bureau of Industry and Security (BIS) ,
Cybersecurity ,
Economic Sanctions ,
Entity List ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
General Licenses ,
Huawei ,
Telecommunications ,
U.S. Commerce Department
OFAC outlines baseline considerations for evaluating a risk-based sanctions compliance program.
On May 2, 2019, the US Treasury Department’s Office of Foreign Assets Control (OFAC) published A Framework for OFAC Compliance...more
5/9/2019
/ Audits ,
Black & Decker ,
Chief Compliance Officers ,
Compliance ,
Corporate Counsel ,
Corporate Management ,
Economic Sanctions ,
Enforcement Actions ,
Internal Controls ,
Office of Foreign Assets Control (OFAC) ,
Risk Assessment ,
Training
Trump Administration breaks with precedent to allow US plaintiffs to bring “trafficking” suits under Title III of the Helms-Burton Act.
Title III of the Helms-Burton Act (the Cuban Liberty and Democratic Solidarity...more
OFAC adds PdVSA to its sanctions list and simultaneously issues general licenses temporarily allowing certain transactions and activities involving PdVSA.
On January 28, the US Treasury Department’s Office of Foreign...more
OFAC added several parties to the SDN List and simultaneously issued a General License, authorizing certain wind-down activities until January 8, 2020.
Today, the Treasury Department’s Office of Foreign Assets Control...more
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
11/6/2018
/ Economic Sanctions ,
EU ,
Financial Institutions ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
General Licenses ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Secondary Sanctions ,
Trump Administration
Withdrawal from the JCPOA will lead to re-imposition of several categories of US sanctions.
On May 8, 2018, President Trump announced that the United States will withdraw from the Joint Comprehensive Plan of Action...more
President Trump issues an Executive Order prohibiting certain transactions involving the Venezuelan government and state-owned or state-controlled entities.
Key Points:
..The Executive Order imposes new sanctions that...more
On December 17, 2014, President Obama announced that the United States would “chart a new course” on its Cuba policy. Starting in January 2015, and for the next two years, the Treasury Department’s Office of Foreign Assets...more
Trump administration expected to maintain changes, but certain restrictions remain.
In the final days of his administration, President Obama announced significant changes to the US embargo against Sudan, in place since...more
Various factors continue to shape and limit trade and investment between Iran and the rest of the world.
Six months have passed since the implementation of the nuclear agreement with Iran, officially known as the Joint...more
Privy Council clarifies the nature of arbitration clauses, but uncertainties about the clauses’ effect still remain.
“Non-exclusive” arbitration clauses provide that disputes “may” be referred to arbitration (rather than...more
7/14/2016
/ Arbitration Agreements ,
Arbitration Awards ,
Arbitrators ,
Bilateral Investment Treaties ,
Canada ,
Conflicts of Interest ,
Enforceability ,
EU ,
Financial Institutions ,
Forum Selection ,
Free Trade Agreements ,
ICSID ,
Implementation Day ,
International Arbitration ,
International Chamber of Commerce (ICC) ,
Investor State Dispute Settlement (ISDS) ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Restitution ,
Romania ,
SDN List ,
Sovereign Immunity ,
SWIFT ,
Switzerland ,
Venezuela ,
Zimbabwe
The EU and UN terminate most of their sanctions on Iran, while the US implements more limited changes to its longstanding embargo.
On January 16, 2016, the International Atomic Energy Agency (IAEA) verified that Iran...more
Recent and upcoming milestones fuel expectations of Iran opportunities in 2016.
As reported in our Client Alert dated July 16, 2015, the Joint Comprehensive Plan of Action (JCPOA) provides for the eventual termination of...more
The Iran sanctions landscape is poised to change in early 2016, but US persons and US companies will see far fewer opportunities than their European counterparts.
On July 14, 2015, the P5+1 countries (the United...more
7/17/2015
/ Aircraft ,
Aircraft Equipment ,
EU ,
Export Controls ,
IAEA ,
Imports ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Nuclear Power ,
Nuclear Weapons ,
P5+1 Nations ,
Popular ,
Trade Relations ,
UN Security Council ,
United Nations