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The United States Updates Sanctions to Combat Terrorism with New Focus on Non-U.S. Banks

As it targets terrorist groups and their finances, the U.S. Government announces potent secondary sanctions that can impede correspondent banking relationships of non-U.S. banks. A new U.S. Executive Order updates the...more

Four China Nuclear Industry Companies Added to “Entity List”

China General Nuclear Power Group (CGN) and three of its affiliates have been added to the Commerce Department’s Entity List. China General Nuclear Power Group (CGN) and affiliates China General Nuclear Power Corporation...more

Huawei Remains on the BIS Entity List but Senior Officials Suggest Export Licenses May Be Considered

As trade relations with China continue to evolve, Huawei Technologies Co., Ltd. (“Huawei”) and its foreign affiliates remain subject to broad U.S. export license requirements. ...more

Cuba Travel Update: U.S. Regulators Amend Key Rules

On June 5, 2019, the Department of Commerce Bureau of Industry and Security (BIS) amended an important license exception which generally permitted the temporary sojourn of civil aircraft and vessels to Cuba.  ...more

Temporary General License Grants Huawei Limited Relief from Restrictions Imposed by Entity List Restrictions

On May 16, 2019, the Bureau of Industry and Security (BIS) of the U.S. Department of Commerce added Huawei Technologies Co., Ltd. (Huawei) and sixty-eight of its non-U.S. affiliates to the Entity List, thereby prohibiting the...more

U.S. Targets Huawei and Telecommunications Trade

On 15 May 2019, the U.S. government made two major announcements that are expected to disrupt the telecommunications equipment, technology, software and services sector....more

U.S. Commerce Department Releases Proposed Rulemaking for Export Controls on Emerging Technologies

On November 19, 2018, the US Commerce Department’s Bureau of Industry and Security (BIS) issued a proposed rulemaking seeking public comment on criteria for identifying emerging technologies that are essential to U.S....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

Completing “Snap-Back”

On November 2, 2018, the Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued a final rule effective Monday, November 5, 2018 that amends the Iranian Transactions and Sanctions Regulations and reinstates...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

With CDD and Beneficial Ownership Rule in Effect, FinCEN Continues to Clarify and Refine Rules for Financial Institutions

Long awaited rules for “Customer Due Diligence Requirements for Financial Institutions” (the CDD Rules) went into effect on May 11, 2018. FinCEN has taken steps to clarify and refine implementation of the CDD Rules, issuing...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

U.S. Targets Human Rights Abusers and Corrupt Actors Worldwide – Key Takeaways from the Potent New Sanctions

On December 20, 2017, President Trump issued Executive Order 13818 (the “E.O.”) implementing provisions of the Global Magnitsky Human Rights Accountability Act (“Global Magnitsky Act”) (enacted into law in December 2016),...more

Large Whistleblower Award to Non U.S. Person- Lessons for Anti-Corruption Compliance Programs

On December 5, 2017 the Securities and Exchange Commission (“SEC”) awarded more than $4.1 million to a whistleblower for alerting the SEC to a multi-year securities fraud engaged in by his employer. The award is significant...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

A UK Version of OFAC?

The Office of Financial Sanctions Implementation ramps up enforcement activities in London - A new UK sanctions enforcement body with added civil enforcement tools is ramping up activities. ...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

Three Birds with One Stone: New Russia, North Korea and Iran Sanctions

On August 2, 2017, President Trump signed into law the Countering America’s Adversaries Through Sanctions Act (CAATSA), which strengthened U.S. sanctions on Russia, North Korea and Iran. CAATSA had been passed by overwhelming...more

OFAC Updates FAQs on the Cuba Sanctions Program

On June 16, 2017, President Trump issued a National Security Presidential Memorandum on Strengthening the Policy of the United States Toward Cuba, which began the process to alter some aspects of U.S. policy toward Cuba. On...more

A Message to China? New U.S. Sanctions and AML Measures for North Korea

On June 29, 2017, the U.S. Treasury Department announced new steps applying pressure on North Korea in relation to its proliferation activities. Specifically, this involved (1) sanctions designations against Chinese shipping...more

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