In the days before former President Joe Biden left office, the U.S. announced two new rounds of sanctions against Russia, including expansive new sanctions against Russia’s energy sector. According to its press release, the...more
Key Points -
- Political transitions in the West notwithstanding, we expect economic sanctions to remain a key response to geopolitical issues.
- Current sanctions policy priorities are unlikely to shift markedly in...more
1/20/2025
/ China ,
Cybersecurity ,
Data Security ,
Economic Sanctions ,
Enforcement Actions ,
EU ,
Export Controls ,
Extraterritoriality Rules ,
Financial Services Industry ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Regulatory Requirements ,
Russia ,
Sanctions ,
UK ,
Whistleblowers ,
White Collar Crimes
On October 29, 2024, the U.S. Department of Justice (DOJ) published a proposed rule (Proposed Rule) that would restrict or prohibit certain transactions with China, Russia and other countries of concern involving U.S....more
12/18/2024
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Biden Administration ,
China ,
Compliance ,
Covered Person ,
Data Security ,
Department of Justice (DOJ) ,
Executive Orders ,
International Data Transfers ,
Prohibited Transactions ,
Proposed Rules ,
Regulatory Agenda ,
Regulatory Requirements ,
Risk Management ,
Russia ,
Sensitive Personal Information ,
Trump Administration
The past weeks and months have brought about tremendous political change in the West, as we move toward a new U.S. administration, a new College of Commissioners in Brussels and a new Polish presidency of the Council of the...more
11/13/2024
/ Capital Markets ,
CFIUS ,
China ,
Corporate Counsel ,
Economic Sanctions ,
Enforcement Actions ,
EU ,
Export Controls ,
Extraterritoriality Rules ,
Financial Institutions ,
Middle East ,
National Security ,
Regulatory Requirements ,
Russia ,
Sanctions ,
Tariffs ,
Trump Administration ,
UK ,
Ukraine ,
US Trade Policies ,
Whistleblowers
On April 24, 2024, President Joe Biden signed the 21st Century Peace Through Strength Act (Act) into law. The Act, which is part of a broader law providing supplemental aid to Israel, Taiwan and Ukraine, contains several...more
6/3/2024
/ Anti-Money Laundering ,
Biden Administration ,
CFIUS ,
Economic Sanctions ,
EU ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Statute of Limitations ,
TWEA ,
UK
On April 24, 2024, President Joe Biden signed into law a high-profile package of national security legislation (Public Law 118-50). While most press reports focused on the spending elements of the package (appropriating funds...more
5/3/2024
/ Asset Freeze ,
Asset Seizure ,
Economic Sanctions ,
Export Controls ,
International Trade ,
Investors ,
Joe Biden ,
Legislative Agendas ,
National Security ,
New Legislation ,
Russia ,
Ukraine
Through a series of coordinated actions in May 2023, the United States launched a whole-of-government effort to expand and strengthen enforcement of its sanctions campaign against Russia as the conflict in Ukraine continues...more
6/6/2023
/ Anti-Money Laundering ,
Bureau of Industry and Security (BIS) ,
CFIUS ,
Economic Sanctions ,
Export Controls ,
Financial Institutions ,
FinCEN ,
International Trade ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Russia
DOJ Increases Resources To Investigate and Prosecute Sanctions Evasion and Export Control Violations -
On March 2, 2023, during a keynote speech at the American Bar Association’s annual White Collar Crime National...more
3/17/2023
/ Anti-Corruption ,
Bureau of Industry and Security (BIS) ,
Compliance ,
Corporate Entities ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Economic Sanctions ,
EU ,
Export Controls ,
Exports ,
Financial Institutions ,
Foreign Corrupt Practices Act (FCPA) ,
International Trade ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Self-Disclosure Requirements ,
U.S. Commerce Department ,
U.S. Treasury ,
UK ,
Voluntary Disclosure
On February 24, 2023, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced four new rules expanding restrictions on exports to Russia and Belarus. The revisions to the Export Administration...more
The withdrawal of Western companies from Russia in the wake of the war in Ukraine has garnered a lot of attention. But the process does not take place overnight, and many foreign companies that have operated in Russia face...more
12/16/2022
/ Acquisitions ,
Best Practices ,
Economic Sanctions ,
EU ,
Exit Transactions ,
Export Controls ,
Foreign Investment ,
Investment ,
Jurisdiction ,
Russia ,
UK ,
Ukraine
On December 5, 2022, the price cap on Russian crude oil that was announced by the G-7 finance ministers in September 2022 went into effect at a level of $60 per barrel. The price cap is implemented by prohibiting the...more
In light of the recent referendums and purported annexation by Russia of four territories of Ukraine on September 30, 2022, the United States, United Kingdom and European Union have expanded measures and provided additional...more
10/14/2022
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
EU ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Foreign Policy ,
Foreign Relations ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
UK ,
Ukraine
Even though significant sanctions and export controls have already been put in place, the United States recently adopted additional measures targeting key elements of the Russian economy and military industry in response to...more
Since the publication of our March 24, 2022, and March 17, 2022, client alerts, the U.S., U.K. and European Union, among other allied nations, have imposed additional sanctions and export controls on key elements of the...more
5/2/2022
/ Blocking Sanctions ,
Economic Sanctions ,
EU ,
European Commission ,
Export Controls ,
Exports ,
Financial Institutions ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
UK
On March 11, 2022, President Joe Biden signed Executive Order 14068 (E.O. 14068) imposing new restrictions on imports and exports with respect to Russia as well as on the supply of U.S. dollar-denominated banknotes to the...more
3/22/2022
/ Bank Notes ,
Banks ,
Biden Administration ,
Economic Sanctions ,
Executive Orders ,
Export Controls ,
Exports ,
Financial Institutions ,
Luxury Goods ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Ukraine
On March 8, 2022, President Joe Biden issued Executive Order (E.O.) 14066, which bans the import of Russian oil, gas and other energy products into the United States and imposes sweeping prohibitions on new U.S. investment in...more
Since the publication of our February 26, 2022, client alert, the United States, United Kingdom and the European Union, among other allied nations, have imposed additional sanctions and export controls on key elements of the...more
3/10/2022
/ Belarus ,
Blocking Sanctions ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Controls ,
Financial Institutions ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
SWIFT ,
Ukraine
The United States, United Kingdom and the European Union, among other allies, have moved swiftly in response to the Russian Federation’s invasion of Ukraine. Merely hours after Russia’s announcement on February 21, 2022, that...more