Ruling holds that the government cannot use conspiracy and accomplice liability theories to reach foreign nationals that lack US ties.
Key Points:
..Non-resident foreign nationals who are not otherwise subject to direct...more
In light of the EU’s recent amendments to its long-standing blocking measure, EU operators will need to weigh the consequences of failing to comply with their contradicting obligations under US and EU law.
How has the EU...more
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
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
4/13/2018
/ Blocked Person ,
CAATSA ,
Economic Sanctions ,
Executive Orders ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Secondary Sanctions ,
Trump Administration ,
U.S. Treasury ,
Ukraine
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
4/10/2018
/ Blocked Person ,
CAATSA ,
Economic Sanctions ,
Executive Orders ,
Financial Institutions ,
General Licenses ,
Government Officials ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
State-Owned Enterprises ,
Trump Administration ,
U.S. Treasury
Treasury Department Report identifies 114 senior political figures and 96 oligarchs, and confirms that the Report is not a sanctions list -
On January 29, 2018, the Treasury Department submitted a report to the US Congress...more
Treasury Department Report identifies 114 senior political figures and 96 oligarchs, and confirms that the Report is not a sanctions list -
On January 29, 2018, the Treasury Department submitted a report to the US...more
The revised FCPA Corporate Enforcement Policy signals DOJ’s emphasis on corporate voluntary self-disclosure, rewarding cooperating companies with a presumption in favor of declination and reductions in penalties.
...more
Venezuela’s initiative is unlikely to set the stage for a restructuring of international obligations in the face of US sanctions.
Key Points:
- US sanctions will prohibit US persons from engaging in a restructuring of...more
President Trump signs the “Countering America’s Adversaries Through Sanctions Act,” which — among other measures — requires Congressional review to ease Russia-related sanctions.
On Wednesday, August 2, 2017, President...more
9/16/2017
/ Asset Freeze ,
Congressional Authority ,
Cybersecurity ,
Economic Sanctions ,
Foreign Relations ,
Human Rights ,
Iran ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Pipelines ,
Russia ,
SDN List ,
Secondary Sanctions ,
Terrorism Funding ,
Trump Administration
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
President Trump signs the “Countering America’s Adversaries Through Sanctions Act,” which — among other measures — requires Congressional review to ease Russia-related sanctions.
On Wednesday, August 2, 2017, President...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
The Guidance parallels the DOJ approach under the FCPA, but does not specify the value of mitigation and may create contradictory incentives.
The National Security Division (NSD) of the US Department of Justice (DOJ)...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
As deadline for nuclear agreement approaches, any easing of sanctions will be gradual, and global businesses will continue to face compliance and enforcement risks.
This Client Alert outlines the approaches the US...more
Ten key changes to US sanctions and export regulations for Cuba.
On January 15, 2015, the Departments of the Treasury and Commerce revised the Cuban Assets Control Regulations (CACR) and the Export Administration...more
New US rules define scope of prohibitions and authorized activities, as Crimea region remains subject to broad US embargo and EU trade and investment restrictions.
On January 29 and 30, 2015, the US Department of...more
New regulations will facilitate trade and investment in Cuba, including air travel and telecommunications to and within the island.
On January 15, 2015, the Departments of the Treasury and Commerce revised the Cuban...more
1/21/2015
FCPA Opinion Release provides insight into the jurisdictional reach of the FCPA and the level of due diligence the DOJ expects.
On November 7, 2014, the US Department of Justice (DOJ) issued its second and final...more
While signalling a dramatic shift in the US-Cuba relationship, the President’s authority to lift sanctions is limited in several key respects.
On December 17, 2014, President Obama announced that the United States will...more