FOURTH QUARTER 2019 -
- Congress closes the year by passing new sanctions against China over human rights concerns, while OFAC clarifies the scope of recent actions against Chinese shipping companies.
- In the wake of...more
1/15/2020
/ AML/CFT ,
China ,
Compliance ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Export Controls ,
Exxon Mobil ,
Human Rights ,
Iran ,
Iran Sanctions ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Sanctions ,
Voluntary Disclosure
Closing out 2018, OFAC announced its plan to lift sanctions against United Co. Rusal and others, despite bi-partisan opposition from Congress. Simultaneously, OFAC continued to target Russia’s defense and intelligence sectors...more
1/23/2019
/ Counter-Terrorist ,
Drug Trafficking ,
Economic Sanctions ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
General Licenses ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Magnitsky Act ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Trafficking ,
Trump Administration ,
Venezuela
This quarter, companies around the globe prepared to exit Iran-related business in the wake of U.S. sanctions snap-back. Meanwhile, OFAC provided a path to relief to designated Russian entities, extending several deadlines...more
7/12/2018
/ Counter-Terrorist ,
Drug Trafficking ,
Economic Sanctions ,
Enforcement Actions ,
Foreign Policy ,
General Licenses ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Magnitsky Act ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
South Korea ,
Trump Administration ,
Ukraine ,
Venezuela
The U.S. exit from the Iran Deal and the return of U.S. sanctions on Iran will impact companies located around the world, particularly if they conduct some part of their business in the U.S. Partner Philip Urofsky...more
President Trump announced today the United States’ withdrawal from the Joint Comprehensive Plan of Action and initiated plans to re-impose nuclear-related sanctions that had been suspended under the terms of the 2015 nuclear...more
This quarter saw the announcement of sweeping new sanctions against Russia’s billionaire class and their corporate holdings, and included the Trump Administration’s first issuance of sanctions against Russia for meddling in...more
4/16/2018
/ CAATSA ,
Counter-Terrorist ,
Criminal Prosecution ,
Drug Trafficking ,
Economic Sanctions ,
General Licenses ,
Iran Sanctions ,
Narcotics ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanction Violations ,
SDN List ,
SSI List ,
Terrorism Funding ,
Trump Administration ,
Ukraine ,
Venezuela
It has now been two years since Iran-related sanctions relief took effect under the Joint Comprehensive Plan of Action. While U.S. persons continue to be generally prohibited from engaging in Iran-related business, the JCPOA...more
Headlines from the final months of 2017 included the signing of a new executive order with global anti-corruption implications; new guidance on the Trump Administration’s approach to Russia sanctions under CAATSA; tightening...more
1/9/2018
/ Counter-Terrorist ,
Cuba ,
Drug Trafficking ,
Economic Sanctions ,
Executive Orders ,
Iran Sanctions ,
Magnitsky Act ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sudan ,
Trump Administration
The third quarter was headlined by the imposition of broad new US legislative sanctions against Russia, Iran, and North Korea. The Trump Administration also acted unilaterally to significantly expand sanctions against both...more
The first six months of the Trump Administration saw several notable developments for US sanctions, with particular implications for Russia and Iran. The Administration also declared a shift in US policy toward Cuba. ...more
7/6/2017
/ Counter-Terrorist ,
Cuba ,
Drug Trafficking ,
Economic Sanctions ,
Enforcement Actions ,
Exxon Mobil ,
Foreign Policy ,
Iran Sanctions ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Proposed Legislation ,
Russia ,
Trump Administration ,
Ukraine
On November 8, 2016, Donald John Trump was elected the 45th President of the United States. Following fiery criticism of the Obama Administration’s sanctions policies, including the Iran deal, the lifting of substantial parts...more
On December 15, 2016, the Office of Foreign Assets Control revised its Frequently Asked Questions guidance that concerns the re-imposition of sanctions in the event of a sanctions snapback under the Joint Comprehensive Plan...more
OFAC amends the Cuban Assets Control Regulations to ease Cuban sanctions in response to President Obama’s policy changes announced on December 17, 2014. These revisions have major implications for the banking and financial...more
4/18/2016
/ Boeing ,
Cuban Assets Control Regulations (CACR) ,
EU ,
General Licenses ,
Iran Sanctions ,
Myanmar ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sudan ,
Syria ,
United Nations
The International Atomic Energy Agency certifies that Iran had complied with all nuclear-related requirements of the Joint Comprehensive Plan of Action leading to the end of United States sanctions against the country...more
Although the United States, the European Union, and the United Nations lifted a number of sanctions targeting Iran on January 16, 2016 (“Implementation Day”) in accordance with the terms of the recent Iran nuclear deal, the...more
Although US and EU sanctions targeting Iran are not likely to be lifted before early 2016, there are a number of issues which US and EU-based financial institutions should be aware of in preparation for sanctions relief as a...more
9/28/2015
/ Banking Sector ,
EU ,
Financial Institutions ,
Implementation Day ,
International Atomic Energy Agency ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
P5+1 Nations ,
SDN List
After almost two years of negotiations, the P5+1 and Iran reach a final comprehensive agreement regarding Iran’s nuclear program, which will likely result in the gradual lifting of international and US sanctions by early next...more
8/4/2015
/ Cuba ,
Enforcement Actions ,
IAEA ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Nuclear Weapons ,
Office of Foreign Assets Control (OFAC) ,
P5+1 Nations ,
Sanctions ,
State Sponsors of Terrorism
On July 22, 2015, Shearman & Sterling hosted a client call on Iran sanctions led by Dan Newcomb, Anthony Patten, Barney Reynolds and James Campbell to examine the impact of this historic agreement and discuss how companies...more
After almost two years of negotiations, on July 14, 2015, the E3/EU+3 (China, France, Germany, Russia, the United Kingdom and the United States) and Iran reached an agreement regarding Iran’s nuclear program. The Joint...more
7/16/2015
/ Banking Sector ,
Energy Sector ,
Foreign Relations ,
IAEA ,
Inspections ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Nuclear Power ,
P5+1 Nations ,
SDN List ,
Trade Relations
What are the prospects for business with Iran after the June 30 deadline to complete negotiations over Iran’s nuclear program? In exchange for limitations on Iran’s ability to develop nuclear weapons, the European Union...more
In this issue:
- The Revised OFAC 50 Percent Rule
- U.S. and E.U. Sectoral Sanctions Targeting Russia
- Additional U.S. Sanctions Targeting Iran
- Sanctions Targeting Ongoing Conflicts in Syria,...more
10/21/2014
/ Banking Sector ,
Defense Sector ,
Energy Sector ,
Enforcement Actions ,
EU ,
Iran Sanctions ,
Joint Plan of Action ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SSI List ,
Sudan ,
Syria ,
Ukraine
In this edition:
- Implementation of the Joint Plan of Action with Iran
- Additional US Iran-Related Sanctions and Licenses
- OFAC Civil Settlements
- US and EU Sanctions in Response to the Situation in...more
As 2013 drew to a close, a potentially groundbreaking agreement was reached with Iran regarding its nuclear program, leading to much speculation about how certain sanctions might be suspended, and under what conditions. While...more
After years of fitful progress and failure, Iran and the five permanent members of the United Nations Security Council (China, France, Russia, the United Kingdom, and the United States) and Germany (collectively the “P5+1”)...more
It has been over eight months since SEC-registered issuers began making mandatory disclosures of business activities in or with Iran. During that period, issuers have filed over 400 Iran Notices with the SEC, including...more