On December 22, 2023, President Biden issued a new Russia-related Executive Order (“EO”) targeting foreign financial institutions (“FFIs”) that support Russia’s military-industrial base. The new EO allows the U.S. government...more
The U.S. Government has imposed additional punitive measures against Russia in response to Russia’s actions in Ukraine. The new measures include a prohibition on imports of Russian gold into the United States, new SDN and...more
7/5/2022
/ Blocking Sanctions ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Controls ,
FinCEN ,
Foreign Policy ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
State-Owned Enterprises ,
Supply Chain ,
Ukraine
The Office of Foreign Assets Control (“OFAC”) issued General License (“GL”) No. 22 on May 12, 2022, authorizing transactions that are ordinarily incident and necessary to activities that occur in specified, non-regime held...more
The Court of Justice of the EU has interpreted for the first time the Blocking Regulation. The ruling confirms that it is possible to terminate contracts with a US designated person without providing reasons. However, in...more
On 15 April 2021, the U.S. Government announced a number of new sanctions measures against Russia, targeting a variety of “harmful foreign activities” contrary to U.S. foreign policy. ...more
4/21/2021
/ Biden Administration ,
Crimea ,
Critical Infrastructure Sectors ,
Defense Sector ,
Economic Sanctions ,
Executive Orders ,
Financial Institutions ,
Foreign Policy ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
SolarWinds ,
Sovereign Debt ,
State-Owned Enterprises ,
Technology Contracts
On 18 December 2020, BIS added over 70 entities to the Entity List, including Semiconductor Manufacturing International Corporation (SMIC) of China. Most of these entities are subject to a presumption of denial for licenses...more
The Cuban Assets Control Regulations have been amended to prohibit U.S. persons from lodging at certain properties in Cuba, incorporate restrictions on imports of Cuban alcohol and tobacco, and revoke general licenses...more
The Commerce Department’s Bureau of Industry and Security has announced an Interim Final Rule amending the Export Administration Regulation’s General Prohibition Three, the foreign-produced direct product rule....more
5/18/2020
/ Bureau of Industry and Security (BIS) ,
China ,
Comment Period ,
Commerce Control List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Policy ,
Huawei ,
Prohibited Transactions ,
Supply Chain ,
Telecommunications ,
U.S. Commerce Department
As of 16 March 2020 Iran Air and a number of other entities were placed on the Bureau of Industry and Security's (BIS) Entity List.
Summary -
Companies that use Iran Air as transport, particularly companies engaging in...more
3/17/2020
/ Airlines ,
Aviation Industry ,
Bureau of Industry and Security (BIS) ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Foreign Policy ,
General Licenses ,
Iran ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Prohibited Transactions
On 10 January 2020, in response to missile attacks by the Iranian military targeting two U.S. bases in Iraq, the United States Department of the Treasury, Office of Foreign Assets Control (OFAC) designated a number of senior...more
1/14/2020
/ Blocked Person ,
Construction Project ,
Economic Sanctions ,
Executive Orders ,
Foreign Policy ,
Foreign Relations ,
Goods or Services ,
Iran ,
Iran Sanctions ,
Manufacturers ,
Mining ,
Office of Foreign Assets Control (OFAC) ,
Prohibited Transactions ,
SDN List ,
Textiles ,
Trump Administration
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
10/18/2019
/ Blocked Person ,
Economic Sanctions ,
Executive Orders ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Syria ,
Trump Administration ,
Turkey ,
Unauthorized Transactions
On 5 August 2019 the Trump administration issued Executive Order 13884 (the executive order) imposing sweeping sanctions against the government of Venezuela, including its agencies and instrumentalities as well as any...more
On 2 May 2019, the U.S. Treasury's Office of Foreign Assets Control ("OFAC"), the agency responsible for enforcing economic sanctions, published "A Framework for OFAC Compliance Commitments" (the "Framework") which outlines...more
7/3/2019
/ Cooperative Compliance Regime ,
Economic Sanctions ,
Failure to Comply ,
Foreign Policy ,
Foreign Relations ,
Framework Agreement ,
Fund Managers ,
Internal Controls ,
Investment Funds ,
Investment Management ,
Office of Foreign Assets Control (OFAC) ,
Private Equity ,
Risk Assessment ,
Sanction Violations
On 5 November 2018 the United States re-imposed the remaining nuclear-related secondary sanctions administered by the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) against Iran that previously had...more
11/8/2018
/ Economic Sanctions ,
Financial Institutions ,
Foreign Policy ,
Iran ,
Iran Sanctions ,
ITSR ,
Joint Comprehensive Plan of Action (JCPOA) ,
Nuclear Weapons ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
SDN List ,
Shipping Cargo ,
Trump Administration
The United States has begun re-imposing nuclear-related sanctions with respect to Iran in connection with the expiration of the 90-day wind-down period announced alongside the United States' 8 May 2018 withdrawal from the...more
8/13/2018
/ Economic Sanctions ,
Energy Sector ,
Financial Institutions ,
Foreign Investment ,
Foreign Policy ,
Foreign Relations ,
Insurance Industry ,
Iran ,
Iran Sanctions ,
ITSR ,
Nuclear Weapons ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Shipping
In furtherance of President Trump’s 8 May 2018 announcement that the United States would withdraw from the Iran nuclear deal—the Joint Comprehensive Plan of Action (JCPOA)—on 27 June 2018, the U.S. Department of Treasury’s...more
On 9 November 2017, the Trump Administration implemented new regulations to support its change to U.S. policy on Cuba. The U.S. Government has created a new Cuba Restricted List administered by the State Department. Through...more
On 27 October, the U.S. Department of State published guidance with respect to Russia’s Defense and Intelligence sectors under section 231 of the Countering America’s Adversaries The Sanctions Act (CAATSA). Section 231...more
Press reports indicate that President Trump intends to “de-certify” the Iran nuclear deal this week. In practical terms, that means he would refuse to re-certify one or more statutory elements of a law passed by the U.S....more
Effective August 25, 2017, President Trump issued a new Executive Order, (the Order), which targets the Government of Venezuela’s (GOV) and Petroleos de Venezuela, S.A.’s (PdVSA) ability to access capital from the United...more
On Friday, February 3, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) announced it was designating 25 entities and individuals as Specially Designated Nationals (SDNs) for their involvement in...more
2/14/2017
/ Foreign Policy ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
National Security ,
Nuclear Weapons ,
Office of Foreign Assets Control (OFAC) ,
Procurement Guidelines ,
SDN List ,
Terrorist Threats ,
Trump Administration ,
U.S. Treasury ,
WMD