On the eve of the 2024 Group of Seven (G7) Leaders’ Summit, the United States imposed new sanctions and export control measures against Russia further targeting sanctions evaders and, for the first time, the Russian...more
6/19/2024
/ Asset Seizure ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
EU ,
Export Administration Regulations (EAR) ,
Export Controls ,
Financial Services Industry ,
Foreign Financial Institutions (FFI) ,
Information Technology ,
Infrastructure ,
International Securities Market (ISM) ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
SDN List ,
Software ,
UK
On the second anniversary of the start of the war in Ukraine and in response to the death of activist Aleksey Navalny in a Russian prison, the United States, European Union, and United Kingdom, along with Australia and...more
3/4/2024
/ Asset Freeze ,
Australia ,
Bureau of Industry and Security (BIS) ,
Canada ,
China ,
Economic Sanctions ,
Energy Sector ,
EU ,
Export Controls ,
Financial Services Industry ,
India ,
Mining ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Transportation Industry ,
Turkey ,
UK ,
Ukraine ,
United Arab Emirates (UAE) ,
US State Departments
President Biden recently signed into law the Foreign Extortion Prevention Act (“FEPA”), enabling federal prosecution of non-U.S. government officials who solicit or receive bribes.
FEPA complements the Foreign Corrupt...more
1/23/2024
/ Anti-Corruption ,
Anti-Money Laundering ,
Biden Administration ,
Bribery ,
Department of Justice (DOJ) ,
Economic Sanctions ,
FEPA ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Official ,
Securities Exchange Act of 1934 ,
Wire Fraud
Throughout December, the United States, European Union, and United Kingdom adopted a series of new sanctions packages against Russia that are expansive and multilayered and pose additional compliance challenges.
The new...more
1/11/2024
/ Compliance ,
Economic Sanctions ,
EU ,
Exports ,
Financial Institutions ,
Financial Services Industry ,
Imports ,
Jurisdiction ,
Office of Foreign Assets Control (OFAC) ,
Oil Prices ,
Russia ,
SDN List ,
Software ,
U.S. Treasury ,
UK
The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) recently announced two settlements that underscore OFAC’s continued emphasis on companies developing and implementing effective, risk-based...more
In 2022, the US, UK and EU all escalated their sanctions enforcement rhetoric. For example, senior US enforcement officials went so far as to describe sanctions as “the new FCPA” (referring to the US. Foreign Corrupt...more
2/17/2023
/ Civil Sanctions ,
Compliance ,
Economic Sanctions ,
Enforcement ,
EU ,
Liability ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Policies and Procedures ,
Russia ,
UK ,
Ukraine
Since February 2022, the United States, United Kingdom, and European Union have imposed unprecedented economic sanctions on Russia and various Russian entities and individuals in response to the war in Ukraine.
Actions have...more
12/19/2022
/ Asset Freeze ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement ,
EU ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Investment ,
Good Faith ,
Imports ,
Maritime Transport ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Popular ,
Russia ,
Safe Harbors ,
SDN List ,
U.S. Treasury ,
UK ,
Ukraine
Key Takeaways -
A judge has issued an opinion in a first-of-its-kind criminal sanctions case involving the use of virtual currency to evade U.S. economic sanctions. The opinion reinforces the Treasury Department’s position...more
Background As noted in our prior update, the United States, European Union and United Kingdom imposed a number of sanctions in connection with Russia’s recognition of the Donetsk and Luhansk regions of Ukraine. ...more
2/28/2022
/ Asset Freeze ,
Biden Administration ,
Economic Sanctions ,
EU ,
Export Controls ,
Financial Transactions ,
Foreign Policy ,
Foreign Relations ,
Foreign Trade Regulations ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
UK ,
Ukraine ,
Vladimir Putin
Russia's Actions -
On February 21, 2022, Russian President Vladimir Putin signed two executive orders recognizing the DNR/LNR Regions as “sovereign and independent states.”...more
2/23/2022
/ Biden Administration ,
Blocked Person ,
Critical Infrastructure Sectors ,
Economic Sanctions ,
Enforcement Priorities ,
Export Controls ,
Financial Transactions ,
Foreign Policy ,
Foreign Relations ,
Foreign Trade Regulations ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Ukraine ,
Vladimir Putin
The United States, Russia, the North Atlantic Treaty Organization (“NATO”) and the Organization for Security and Co-operation in Europe (“OSCE”) held a series of talks this week aimed at de-escalating the situation at the...more
1/14/2022
/ CAATSA ,
Economic Sanctions ,
Financial Services Industry ,
Financial Transactions ,
Foreign Policy ,
International Relations ,
Legislative Agendas ,
NATO ,
Proposed Legislation ,
Regulatory Agenda ,
Russia ,
SDN List ,
Sovereign Debt ,
SWIFT ,
Ukraine ,
US Trade Policies
The U.S.-China trade war continues to escalate, most recently fueled by U.S. concerns over China’s assertion of increasing authority over Hong Kong. The U.S. and Chinese governments have exchanged jabs through the use of...more
7/17/2020
/ CFIUS ,
China ,
Criminal Prosecution ,
Economic Sanctions ,
Exceptions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Free Speech ,
Free Trade Agreements ,
Freedom of the Press ,
Hong Kong ,
Hong Kong Autonomy Act (HKAA) ,
Human Rights ,
Open General Export Licences (OGELs) ,
Popular ,
Revocation ,
Right to Peaceful Assembly ,
SDN List ,
Section 301 ,
Tariffs ,
Technology Sector ,
Trade Act of 1974 ,
Trade Policy ,
Trade Wars ,
Travel Ban ,
Trump Administration ,
United States
On February 1, 2019, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued guidance in the form of Frequently Asked Questions (“FAQs”) relating to sanctions imposed on January 28, 2019 against...more
2/4/2019
/ Blocked Person ,
Bonds ,
Derivatives ,
Due Diligence ,
Economic Sanctions ,
General Licenses ,
Non U.S. Person ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
SDN List ,
Trump Administration ,
U.S. Treasury ,
Venezuela ,
Winding Down
On January 28, 2019, the United States imposed blocking sanctions on Petróleos de Venezuela SA (“PdVSA”), the Venezuelan state-owned oil company. The measures follow President Trump’s recent decision to recognize Juan Guaidó,...more
1/31/2019
/ Blocked Person ,
Economic Sanctions ,
Energy Sector ,
Executive Orders ,
Financial Institutions ,
Foreign Investment ,
Imports ,
International Emergency Economic Powers Act (IEEPA) ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Presidential Elections ,
SDN List ,
Trump Administration ,
Venezuela ,
Winding Down
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
7/19/2018
/ Blocking Statutes ,
Bonds ,
Cryptocurrency ,
Debt Buyers ,
Debt-Equity ,
Defense Sector ,
Economic Sanctions ,
Energy Sector ,
EU ,
Financial Markets ,
General Licenses ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Popular ,
Russia ,
SDN List ,
Secondary Sanctions ,
Syria ,
Trump Administration ,
Ukraine ,
Venezuela
The Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury issued updated general licenses and related guidance in connection with sanctions imposed in April on certain Russian individuals and entities...more
The U.S. government has recently been active with respect to regulating cryptocurrencies. For its part, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) recently released guidance—issued in the form of...more
4/9/2018
/ Bitcoin ,
Cryptocurrency ,
Economic Sanctions ,
ETFs ,
Executive Orders ,
Hackers ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Venezuela ,
Virtual Currency
The U.S. Government this week announced changes to U.S. sanctions against Cuba to implement various policy changes announced by President Trump in July 2017 (for additional background, see our prior OnPoint from June 2017)....more
11/10/2017
/ Cuba ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Financial Transactions ,
Foreign Policy ,
Government Officials ,
International Travel ,
Open General Export Licences (OGELs) ,
Travel Restrictions ,
Trump Administration
The United States announced new sanctions against the Venezuelan Government on August 25, 2017 that target the government’s ability to access U.S. debt and equity markets. The measures are intended to pressure Venezuelan...more
8/30/2017
/ Debt Instruments ,
Debt-Equity ,
Economic Sanctions ,
Executive Orders ,
Exports ,
General Licenses ,
Human Rights ,
Imports ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
SSI List ,
Trump Administration ,
Venezuela
Yesterday, President Trump signed H.R. 3364, the “Countering America’s Adversaries Through Sanctions Act,” enacting into law limited additional sanctions against Russia and, critically, restricting his ability to suspend or...more
After weeks of discussion and procedural uncertainty, the U.S. House of Representatives passed new legislation by a vote of 419–3 that, if enacted into law, will strengthen existing sanctions against Russia and also impose...more
7/29/2017
/ Congressional Authority ,
Cyber Attacks ,
Economic Sanctions ,
Energy Sector ,
Foreign Relations ,
Hackers ,
Iran ,
Iran Sanctions ,
North Korea ,
Pending Legislation ,
Russia ,
SSI List ,
Trump Administration
President Trump announced just before the weekend that he will reinstate certain travel and commercial restrictions related to Cuba that had been eased under the Obama Administration. While President Trump declared that he...more
U.S. District Court Judge Richard M. Berman denied a motion to dismiss the indictment in the closely followed criminal prosecution of Reza Zarrab, a Turkish/Iranian businessman charged with conspiring to evade U.S. economic...more
10/20/2016
/ Banks ,
Blocked Entities ,
Criminal Conspiracy ,
Criminal Prosecution ,
Economic Sanctions ,
Evasion ,
Extraterritoriality Rules ,
Financial Transactions ,
Foreign Relations ,
Fraud ,
General Licenses ,
Indictments ,
International Emergency Economic Powers Act (IEEPA) ,
International Litigation ,
Iran Sanctions ,
ITSR ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Turkey
The U.S. Department of the Treasury, together with other U.S. government agencies responsible for enforcing anti-money laundering (AML) and economic sanctions regulations, released guidance on August 30, 2016 in the form of a...more
9/1/2016
/ Anti-Money Laundering ,
Compliance ,
Depository Institutions ,
Due Diligence ,
Economic Sanctions ,
Enforcement Actions ,
Foreign Correspondent Banking ,
Foreign Financial Institutions (FFI) ,
Joint Policy Statements ,
New Guidance ,
U.S. Treasury
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) eased certain sanctions against Burma/Myanmar on May 17, 2016, including by allowing most transactions involving Burmese financial institutions....more