In 2023, the European Union continued to use economic sanctions as one of its foreign policy tools, and not only in response to Russia’s war in Ukraine. New sanctions and adjustments to existing regimes reflect the EU’s...more
The sanctions world experienced another action-packed year in 2023. Sanctions against Russia dominated the year in terms of the number of designations and new restrictions, and the attacks perpetrated by Hamas in Israel on 7...more
Current Situation in Iran - A historic and powerful popular movement—led by women in response to the murder of Mahsa Amini while in the custody of the Iranian Morality Police in mid-September—is currently unfolding in...more
Talks between the U.S. and Iran to revitalize the nuclear deal may have stalled but they are far from dead. There is still optimism that the agreement to limit Iran’s ability to make weapons-grade uranium, in return for a...more
In December 2021, the Court of Justice of the European Union (the CJEU) published a judgment interpreting the European Union's Blocking Regulation....more
The European Union Blocking Statute was originally adopted in 1996 to counteract US sanctions on Cuba, Iran and Libya, but following a memorandum of understanding entered into between the EU and the US, it has seldom been...more
In May 2018 the United States announced the reinstitution of sanctions against Iran that had previously been lifted pursuant to the Joint Comprehensive Plan Action (“JCPOA”). The U.S. sanctions on Iran that were revived...more
Report on Supply Chain Compliance 3, no. 19 (October 1, 2020) - The United States argued before the United Nations (UN) that Germany, France and the United Kingdom must support the U.S. demand to reimpose UN sanctions on...more
On 31 March 2020, the Governments of France, Germany, and the United Kingdom (the so-called "E3") confirmed that the first transaction was completed through the Instrument in Support of Trade Exchanges ("INSTEX"),...more
Earlier this month, France, Germany and the UK triggered the dispute process under the Iran nuclear deal, saying they had been "left with no choice" after Iran decided to further reduce compliance with the agreement. The...more
France, Germany and the United Kingdom, known as the “E3”, announced on 14 January 2020 that they had triggered the dispute resolution mechanism under the Joint Comprehensive Plan of Action (“JCPOA”) due to concerns about...more
Europe has come up with a nifty plan to help Iran buy and sell stuff outside the reach of U.S. sanctions. The problem is that the plan is a fraud magnet. How do we know? It’s been tried before, and the fraud was epic. The...more
As part of our periodic updates, here is an overview of recent developments of relevance to participants in the real estate finance market across certain key jurisdictions in Europe....more
On May 8, 2019, following Iran's announcement that it intends to suspend certain nuclear proliferation-related commitments under the Joint Comprehensive Plan of Action (JCPOA), the United States issued a new Executive order...more
With Brexit looming, the UK's autonomous sanctions policy is slowly taking shape. This month saw the publication of regulations setting out the post-Brexit UK sanctions regimes for Iran, Burma and Venezuela, which will come...more
On 31 January 2019, France, Germany and the United Kingdom (the "E3") announced the registration in France of INSTEX SAS ("Instrument for Supporting Trade Exchanges"), which is a special purpose vehicle aimed at facilitating...more
Pursuant to the President’s May 8, 2018, memorandum announcing the United States’ withdrawal from the Joint Comprehensive Plan of Action (JCPOA), the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC)...more
• As of November 5, 2018, the United States concluded the second of two wind-down periods for re-imposition of U.S. sanctions on Iran following the May 8, 2018, announcement that the United States would cease participation in...more
On November 5, 2018, the United States took steps to complete the U.S. withdrawal from the Joint Comprehensive Plan of Action (“JCPOA”), under which the United States – along with its partners in the P5+1 – had previously...more
On November 5, 2018, applicable wind-down periods for certain transactions with Iran ended and the second and final set of U.S. secondary sanctions that had been lifted pursuant to the Iran nuclear deal – the Joint...more
On August 6, 2018 President Trump issued an executive order re-imposing certain sanctions that were lifted under the 2016 Joint Comprehensive Plan of Action ('JCPOA'). These include the prohibition of...more
• On August 6, 2018, following President Trump’s decision to withdraw the United States from the JCPOA, the U.S. government announced the reimposition of sanctions on Iran’s automotive sector, its trade in gold and precious...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
President Donald Trump issued an Executive Order “Reimposing Certain Sanctions with Respect to Iran” (“New Iran E.O.”) on August 6, 2018, authorizing the re-imposition – or “snap-back” – of various sanctions against dealings...more
As expected, following his May 8, 2018, decision to withdraw the United States from the Joint Comprehensive Plan of Action (“JCPOA”), President Trump signed a new Executive Order (“E.O.”) on August 6, 2018, formally...more