The U.S. yesterday commenced the phased re-introduction of its pre-JCPOA extra-territorial sanctions in relation to Iran – with some measures applying immediately, and others from 5 November. The EU has condemned U.S....more
8/9/2018
/ Blocking Statutes ,
China ,
Economic Damages ,
EU ,
European Commission ,
Extraterritoriality Rules ,
Financing ,
Foreign Relations ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Member State ,
Notice Requirements ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Secondary Sanctions ,
Trump Administration
Following the U.S. decision to withdraw from the Joint Comprehensive Plan of Action (JCPOA) and reimpose sanctions on Iran, the EU has confirmed its full commitment to keep the agreement alive for the remaining parties, as...more
6/13/2018
/ Blocking Statutes ,
EU ,
European Commission ,
Exemptions ,
Foreign Relations ,
General Licenses ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Sanction Violations ,
Secondary Sanctions ,
Trade Relations ,
Trump Administration ,
Waivers ,
WTO
President Trump announced today, May 8, 2018, that the United States would withdraw from the Joint Comprehensive Plan of Action (“JCPOA”), the Iran nuclear deal implemented in January 2016. In connection with the...more
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
Public officials from the United States increasingly are making public statements regarding the likelihood that “Implementation Day” – the day on which many US and EU sanctions against Iran will be eased – will arrive in the...more
The United States and European Union took preparatory steps on 18 October 2015 to begin fulfilling their commitments to suspend certain sanctions against Iran pursuant to the Joint Comprehensive Plan of Action (“JCPOA”)...more
10/22/2015
/ Adoption Day ,
Amending Regulation ,
EU ,
Financial Transactions ,
Implementation Day ,
Insurance Litigation ,
International Atomic Energy Agency ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Metals ,
Military Goods ,
Nuclear Power ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
SDN List ,
Shipping ,
UN Security Council
The U.S. Government announced two major sanctions enforcement actions this week that reinforce the compliance challenges faced by both U.S. companies with international activities and non-U.S. companies subject to U.S....more
3/30/2015
/ Civil Monetary Penalty ,
Compliance ,
Criminal Penalties ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Guilty Pleas ,
International Emergency Economic Powers Act (IEEPA) ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
PayPal ,
Sanctions ,
Schlumberger ,
Settlement ,
Sudan
On 16 December 2014, President Obama announced that he will sign the Ukraine Freedom Support Act of 2014 (hereinafter the “Act”) into law. As discussed in our update dated 12 December 2014, the Act represents a potentially...more
As noted in previous updates, the United States and European Union continue to impose sanctions against Ukrainian and Russian individuals and entities as a result of the turmoil in Ukraine. On 11 December 2014, the US Senate...more
The U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) revised its guidance with respect to entities owned 50 percent or more in the aggregate by more than one blocked persons. The new guidance, issued on...more
In response to recent events in Ukraine, the United States and European Union imposed yet another round of sanctions this week. In response, Russia is considering a number of countermeasures that may affect U.S. and EU...more
Recent enforcement actions brought by the U.S. Government against non-U.S. banks for violations of U.S. sanctions laws demonstrate the need for financial institutions, particularly those that act as custodians or financial...more
1/30/2014
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banks ,
Compliance ,
FinCEN ,
Foreign Banks ,
Iran ,
ITSR ,
Office of Foreign Assets Control (OFAC) ,
Sanctions ,
U.S. Treasury