On 2 August the United States announced that it will impose a second round of sanctions on Russia pursuant to the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (CBW Act) (22 U.S.C. § 5601 et...more
On 5 August 2019 the Trump administration issued Executive Order 13884 (the executive order) imposing sweeping sanctions against the government of Venezuela, including its agencies and instrumentalities as well as any...more
On 20 June 2019 the Department of Treasury's Office of Foreign Assets Control (OFAC) issued a final interim rule (effective on 21 June 2019) amending its reporting, procedures, and penalties regulations, 31 Code of Federal...more
7/26/2019
/ Confidential Information ,
Disclosure Requirements ,
Economic Sanctions ,
Factoring Transactions ,
FOIA ,
Food Marketing Institute v Argus Leader Media ,
Interim Rule ,
License Applications ,
Office of Foreign Assets Control (OFAC) ,
Recordkeeping Requirements ,
Regulatory Oversight ,
Regulatory Requirements ,
Reporting Requirements
On 2 May 2019, the U.S. Treasury's Office of Foreign Assets Control ("OFAC"), the agency responsible for enforcing economic sanctions, published "A Framework for OFAC Compliance Commitments" (the "Framework") which outlines...more
7/3/2019
/ Cooperative Compliance Regime ,
Economic Sanctions ,
Failure to Comply ,
Foreign Policy ,
Foreign Relations ,
Framework Agreement ,
Fund Managers ,
Internal Controls ,
Investment Funds ,
Investment Management ,
Office of Foreign Assets Control (OFAC) ,
Private Equity ,
Risk Assessment ,
Sanction Violations
On 2 May 2019 the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) issued "A Framework for OFAC Compliance Commitments" (the framework), which outlines five components OFAC considers to be essential...more
OFAC has announced a Finding of Violation –and not a penalty–against State Street Bank and Trust Co. (SSBT) for processing 45 pension payments totaling under $12,000 on behalf of a pension plan participant who was a US...more
On 28 January 2019, the Department of Treasury’s Office of Foreign Assets Control (OFAC) designated Petróleos de Venezuela, S.A. (PdVSA) as a Specially Designated National (SDN) for operating in the oil sector of the...more
On 19 December 2018, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) submitted a notification to Congress that it plans to terminate sanctions on three major companies originally designated for...more
The past two weeks have entailed a flurry of sanctions developments related to Russia, including the issuance of a new executive order, and the designation of a number of entities by the U.S. Department of the Treasury's...more
The United States has begun re-imposing nuclear-related sanctions with respect to Iran in connection with the expiration of the 90-day wind-down period announced alongside the United States' 8 May 2018 withdrawal from the...more
8/13/2018
/ Economic Sanctions ,
Energy Sector ,
Financial Institutions ,
Foreign Investment ,
Foreign Policy ,
Foreign Relations ,
Insurance Industry ,
Iran ,
Iran Sanctions ,
ITSR ,
Nuclear Weapons ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Shipping
On 8 August, the U.S. Department of State announced that new sanctions would be imposed on Russia pursuant to the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (CBW Act). The sanctions relate to...more
In furtherance of President Trump’s 8 May 2018 announcement that the United States would withdraw from the Iran nuclear deal—the Joint Comprehensive Plan of Action (JCPOA)—on 27 June 2018, the U.S. Department of Treasury’s...more
Today, the Trump Administration designated multiple Russian targets, including several wealthy individuals and their companies, as Specially Designated Nationals (SDNs). These designations of major companies represent the...more
On Monday, 29 January, the U.S. Treasury Department submitted an unclassified report to Congress concerning significant senior political figures and oligarchs in the Russian Federation and Russian parastatal entities.
...more
On 9 November 2017, the Trump Administration implemented new regulations to support its change to U.S. policy on Cuba. The U.S. Government has created a new Cuba Restricted List administered by the State Department. Through...more
On 27 October, the U.S. Department of State published guidance with respect to Russia’s Defense and Intelligence sectors under section 231 of the Countering America’s Adversaries The Sanctions Act (CAATSA). Section 231...more
Yesterday, on October 12, 2017, the U.S. permanently revoked most sanctions against Sudan. This lifting represents the completion of a process that began in January 2017, and was extended in July 2017. ...more
10/13/2017
/ Agricultural Sector ,
Banking Sector ,
Charitable Organizations ,
Commerce Control List ,
Economic Sanctions ,
Export Controls ,
Medical Devices ,
Office of Foreign Assets Control (OFAC) ,
Pharmaceutical Industry ,
SDN List ,
State Sponsors of Terrorism ,
Sudan ,
Universities
Effective August 25, 2017, President Trump issued a new Executive Order, (the Order), which targets the Government of Venezuela’s (GOV) and Petroleos de Venezuela, S.A.’s (PdVSA) ability to access capital from the United...more
On Tuesday, July 25, the U.S. House of Representatives passed H.R. 3364, the Countering America’s Adversaries Through Sanctions Act by a vote of 419-3.
There is some uncertainty, but the legislation is expected to be...more
Ahead of a Constituent Assembly that could re-write the Venezuelan Constitution and dissolve state institutions, the U.S. Treasury Department’s Office of Foreign Assets Control has designated 13 current and former Venezuelan...more
Aerospace, defense, and government services (ADG) companies increasingly rely on international customers and global supply chains to stay competitive in today’s global market. In the United States, ADG companies rely heavily...more
4/19/2017
/ Aerospace ,
CFIUS ,
China ,
Cybersecurity ,
Defense Sector ,
Economic Sanctions ,
Export Controls ,
Foreign Direct Investment ,
India ,
International Relations ,
National Security ,
Outer Space ,
Supply Chain ,
Technology Sector ,
Trump Administration ,
US Trade Policies
On January 13, 2017, the White House, the U.S. Department of Treasury ’s Office of Foreign Assets Control (OFAC) , and the U.S. Department of Commerce ’s Bureau of Industry and Security (BIS) announced a host of policy...more
1/18/2017
/ Africa ,
Aircraft ,
Aircraft Equipment ,
Aircraft Sales ,
Aviation Industry ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Executive Orders ,
Export Controls ,
Exports ,
Financial Institutions ,
Food Supply ,
Insurance Industry ,
Medical Devices ,
Obama Administration ,
Pharmaceutical Industry ,
Prescription Drugs ,
Reinsurance ,
Sudan ,
Transportation Industry
Maintaining a global supply chain brings its share of commercial, financial, and regulatory risks. Increasingly, telecommunications companies with global operations and suppliers are finding that U.S. trade control laws...more
1/16/2017
/ Algorithms ,
Antiboycott Requirements ,
Bureau of Industry and Security (BIS) ,
Commerce Control List ,
ECCNs ,
Economic Sanctions ,
Encryption ,
End-Users ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Risk Mitigation ,
SDN List ,
Software ,
Supply Chain ,
Technology Sector ,
Telecommunications