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U.S. Expands Secondary Sanctions to Iran’s Industrial Sectors

On January 10, 2020, the United States imposed additional sanctions on Iran in the wake of recent tensions between the countries and the continuing broader ‘maximum pressure’ campaign on Iran. ...more

District Court Overturns OFAC Fine Against Exxon

On December 31, 2019, the U.S. District Court for the Northern District of Texas overturned a $2 million fine imposed by the Department of the Treasury’s Office of Foreign Assets Control (OFAC) against ExxonMobil Corp., and...more

Slavery in Supply Chains: CBP Petitions Raise New Forced Labor Compliance Risks

Third-party petitions seeking to ban the importation of goods made with forced labor may affect global supply chains. Petitions are being filed with U.S. Custom and Border Protection seeking to ban the importation into the...more

U.S. State Department Adds New Hotels to Cuba Restricted List

On November 15, 2018, the U.S. State Department added several new Cuban hotels to its List of Restricted Entities and Subentities Associated with Cuba (“Cuba Restricted List”). The recent update includes the additional of 16...more

OFAC Announces Sanctions Against Saudi Arabian Government Officials Pursuant to Global Magnitsky Act

On November 15, 2018, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned 17 officials of the Government of Saudi Arabia for their purported role in the killing of journalist Jamal...more

Reinstatement of Iran Sanctions

On November 5, 2018, OFAC announced a large number of Iran-related sanctions designations and issued guidance on the end of the 180-day wind down period. ...more

State Department Imposes Chemical Weapons Sanctions on Russia

On August 8, 2018, the State Department announced that it had concluded that Russia was responsible for poisoning former double agent Sergei Skripal and his daughter Yulia using the nerve agent Novichok and that it had sent a...more

U.S. Formalizes Snap-Back of Sanctions with New Executive Order

On August 6, 2018, the Treasury Department’s Office of Foreign Assets Control (OFAC) released a new Executive Order to implement the previously announced re-imposition of U.S. sanctions for Iran. ...more

US Announces Withdrawal from JCPOA

Today, President Trump announced his intention to withdraw the United States from the Joint Comprehensive Plan of Action (JCPOA) and to impose the “highest level of economic sanctions” on Iran. The Office of Foreign Assets...more

Treasury Department Designates Russian Oligarchs, Officials, and Entities

The Treasury Department has placed several prominent Russian individuals and companies on the Specially Designated Nationals and Blocked Persons lists (“SDN list”). Several of these parties are Russian billionaires previously...more

Status of the Iran Nuclear Deal and New Sanctions Designations

On January 12, 2018, President Trump issued a statement on the status of the Joint Comprehensive Plan of Action (“Iran nuclear deal”) and the Office of Foreign Assets Control designated 14 individuals and entities in...more

CBP Takes Measures to Enforce Ban on Imports Made With Forced Labor and Sanctions for Forced North Korean Labor in Supply Chains

On November 22, 2017, Apple, Inc. (“Apple”) released a statement confirming reports that its major supplier in China, Foxconn Technology Group (“Foxconn”) has used illegal student labor to assemble the latest version of the...more

Evolving U.S. and UN Sanctions Against North Korea

Following President Trump’s trip to Asia, sanctions policies for North Korea continue to evolve. The U.S. government has strengthened sanctions through legislation and Presidential Executive Orders. Further, it is enforcing...more

U.S. Government Agencies Publish Changes to Cuba Sanctions Program Pursuant to President Trump’s Policy Announcement

On November 8, 2017, the Department of Treasury’s Office of Foreign Assets Control (“OFAC”) and the Department of Commerce’s Bureau of Industry and Security (“BIS”) announced amendments to the Cuban Assets Control Regulations...more

Russia Sanctions under CAATSA – U.S. Updates Rules and Provides Guidance on Enforcement

This week, the U.S. government took several steps to implement sections of the Countering America’s Adversaries Through Sanctions Act of 2017 (CAATSA), with implications for Russia-related sanctions and their enforcement. On...more

Another Market Opens: U.S. Revokes Sudanese Sanctions Program Though Important Limitations Remain in Place

Effective October 12, 2017, the Sudanese Sanctions Regulations (SSR) have been revoked in recognition of the Government of Sudan’s (GOS) sustained positive actions in stopping conflict and improving humanitarian access in...more

New Executive Order Imposes Further Sanctions on Venezuela

Today, President Trump issued an Executive Order (E.O.) providing for sanctions against the Government of Venezuela. The sanctions are structured similar to existing sectoral sanctions on the Russian petroleum sector and...more

U.S. Government Delays Decision on Sudan Sanctions

On July 11, 2017, the President issued an Executive Order (E.O.) extending the review period for the possible permanent revocation of sanctions on Sudan for an additional three months. On January 13, 2017, then-President...more

U.S. Announces End of Myanmar Sanctions – What Will Go and What Remains?

On September 15, 2016, President Obama announced that U.S. economic sanctions on Myanmar (also known as Burma) would end, but the announcement left many questions as to what would change and what sanctions might remain. On...more

Additional Steps to Ease U.S. Sanctions and Export Controls for Cuba prior to Obama Visit

In advance of President Obama’s highly publicized trip to Cuba, the Administration took additional steps to ease restrictions on trade and travel with Cuba. These changes to the Cuban Assets Control Regulations (CACR) and...more

UN and U.S. Sanctions Target North Korea: Impacts for Asia and Beyond

The United Nations and United States recently took significant new steps to expand sanctions on North Korea, with implications for international banking; shipping and port activities; air transport; energy and mining sectors;...more

UN and U.S. Sanctions Target North Korea: Impacts for Asia and Beyond

The United Nations and United States recently took significant new steps to expand sanctions on North Korea, with implications for international banking; shipping and port activities; air transport; energy and mining sectors;...more

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