On May 23, 2025, the Trump administration issued a general license (GL) significantly relaxing the patchwork of restrictions on Syria, long a jurisdiction subject to comprehensive sanctions. This regulatory action followed a...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
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
The Council of the European Union (Council) has updated its EU Best Practices for the Effective Implementation of Restrictive Measures. Published on 3 July 2024, the new version clarifies the threshold for the ownership test...more
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
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 January 17, 2023, U.S. law enforcement authorities in Miami arrested Anatoly Legkodymov, a Russian national and the founder and majority owner of Hong Kong-based virtual currency exchange Bitzlato Ltd., on charges of money...more
2/7/2023
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Crypto Exchanges ,
Cryptocurrency ,
Enforcement Actions ,
EU ,
Financial Crimes ,
FinCEN ,
Law Enforcement ,
Money Laundering ,
NDAA ,
Patriot Act ,
Popular ,
Russia ,
U.S. Treasury ,
Virtual Currency ,
White Collar Crimes
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
The pandemic’s impact may be subsiding, but businesses are encountering new challenges across the globe, including the potential for an economic retrenchment, rising interest rates, shifting regulatory and litigation...more
12/14/2022
/ Acquisitions ,
Anti-Corruption ,
Antitrust Division ,
Banking Sector ,
Big Tech ,
Board of Directors ,
Bonds ,
Borrowers ,
Capital Markets ,
Capital Raising ,
China ,
Climate Change ,
Convertible Notes ,
Corporate Counsel ,
Corporate Governance ,
Corporate Restructuring ,
Creditors ,
Cross-Border ,
Cryptocurrency ,
Digital Assets ,
Due Diligence ,
Economic Sanctions ,
Enforcement ,
Environmental Social & Governance (ESG) ,
EU ,
Executive Compensation ,
Financial Services Industry ,
Forum Selection ,
Investigations ,
IRS ,
Lenders ,
Mergers ,
Money Laundering ,
Partnerships ,
Publicly-Traded Companies ,
Recessions ,
Repurchases ,
Russia ,
Securities ,
Securities and Exchange Commission (SEC) ,
Securities Litigation ,
Shareholders ,
Special Purpose Acquisition Companies (SPACs) ,
Taxation ,
Technology ,
UK ,
Vertical Mergers
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
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
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
This issue of Skadden’s semiannual Cross-Border Investigations Update takes a close look at recent cases, regulatory activity and other key developments, including a review of the first year of GDPR enforcement, analysis of...more
10/3/2019
/ Anti-Money Laundering ,
Appeals ,
Blocking Statutes ,
Bribery ,
CFTC ,
China ,
CLOUD Act ,
Communication Restrictions ,
Compliance ,
Conspiracies ,
Cooperation Agreement ,
Crime (Overseas Production Orders) Act 2019 (the COPO Act) ,
Criminal Prosecution ,
Cross-Border Transactions ,
Cryptocurrency ,
Cybersecurity ,
Deferred Prosecution Agreements ,
Denial of Certiorari ,
Department of Justice (DOJ) ,
Deutsche Bank ,
Disclosure ,
Dodd-Frank ,
Economic Sanctions ,
Enforcement Actions ,
EU ,
EURIBOR ,
Exports ,
Extradition ,
Extraterritoriality Rules ,
Financial Conduct Authority (FCA) ,
Financial Records ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Exchanges ,
France ,
Fraud ,
General Data Protection Regulation (GDPR) ,
Government Investigations ,
Hackers ,
Hungary ,
Imports ,
India ,
Indictments ,
Information Sharing ,
Iran Sanctions ,
Israel ,
Lithuania ,
Money Laundering ,
Morrison v National Australia Bank ,
Multinationals ,
Office of Foreign Assets Control (OFAC) ,
Opioid ,
Pharmaceutical Industry ,
Popular ,
Rate-Rigging ,
SCOTUS ,
Securities and Exchange Commission (SEC) ,
Serious Fraud Office (SFO) ,
Spoofing ,
Subpoenas ,
Swiss Supreme Court ,
Switzerland ,
Tax Crimes ,
Tax Evasion ,
Tax Treaty ,
Turkey ,
UK ,
United States ,
Venezuela ,
Wal-Mart
In April 2019, Secretary of State Mike Pompeo announced that the U.S. government would allow a private right of action, created by Title III of the Cuban Liberty and Democratic Solidarity (Libertad) Act of 1996 (also known as...more
5/10/2019
/ Blocking Statutes ,
Canada ,
Confiscated Property ,
Cuba ,
EU ,
Expropriation ,
FSCS ,
Helms-Burton Act ,
Personal Remittance Caps ,
Private Right of Action ,
Sanction Suspensions ,
Sanctions ,
Third-Party ,
Title III ,
Trafficking ,
Travel Restrictions ,
Treble Damages ,
Trump Administration ,
UK ,
US Department of State
In this issue, we examine the release of the much-anticipated Strategic Hub for Innovation and Financial Technology (FinHub) guidance for analyzing how U.S. federal securities laws apply to initial coin offerings, the...more
4/16/2019
/ Advertising ,
Blockchain ,
California Consumer Privacy Act (CCPA) ,
CNIL ,
Cryptocurrency ,
Default ,
Digital Assets ,
Discovery ,
Distributed Ledger Technology (DLT) ,
Division of Corporate Finance ,
Ethereum ,
EU ,
FinHub ,
France ,
Frozen Assets ,
General Data Protection Regulation (GDPR) ,
Guilty Pleas ,
Initial Coin Offering (ICOs) ,
Investment Contract ,
Motion to Dismiss ,
No-Action Letters ,
NYDFS ,
Offerings ,
Payment Tokens ,
Personal Jurisdiction ,
Plea Agreements ,
Popular ,
Preliminary Injunctions ,
Profits ,
Public Comment ,
Putative Class Actions ,
Safe Harbors ,
Securities ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Securities Fraud ,
Securities Tokens ,
Securities Violations ,
Settlement ,
Smart Contracts ,
Unregistered Securities ,
Virtual Currency
In 2018, the number of blockchain-enabled projects increased sharply as established companies sought to apply distributed ledger technology to their existing business models and startups developed new and disruptive models...more
1/18/2019
/ AML/CFT ,
Blockchain ,
CFTC ,
Commodity Exchange Act (CEA) ,
Cryptocurrency ,
Derivatives ,
Distributed Ledger Technology (DLT) ,
EU ,
FinCEN ,
FinHub ,
General Data Protection Regulation (GDPR) ,
Initial Coin Offering (ICOs) ,
Popular ,
Proposed Legislation ,
Securities and Exchange Commission (SEC) ,
Token Sales ,
Unregistered Securities
This issue of Skadden’s semiannual Cross-Border Investigations Update takes a close look at recent cases, regulatory activity and other key developments, including DOJ guidance on the use of corporate monitors in criminal...more
1/7/2019
/ Anti-Bribery ,
Anti-Corruption ,
Anti-Money Laundering ,
Appeals ,
Attorney-Client Privilege ,
Brazil ,
Bribery ,
BSA/AML ,
China ,
Corporate Counsel ,
Criminal Conspiracy ,
Criminal Convictions ,
Criminal Investigations ,
Cross-Border ,
Cryptocurrency ,
Cyber Attacks ,
Cybersecurity ,
Data Privacy ,
Data Protection Acts ,
Department of Justice (DOJ) ,
Enforcement Actions ,
EU ,
Exports ,
Extraterritoriality Rules ,
FATCA ,
Financial Crimes ,
Foreign Corrupt Practices Act (FCPA) ,
Forex ,
France ,
Government Investigations ,
Guilty Pleas ,
Hackers ,
Imports ,
International Litigation ,
Iran ,
Legal Professional Privilege ,
Libor ,
Litigation Privilege ,
Market Manipulation ,
Money Laundering ,
Multi-Jurisdictional Litigation ,
Multinationals ,
NYDFS ,
Privileged Communication ,
Russia ,
Sanction Violations ,
Securities and Exchange Commission (SEC) ,
Securities Fraud ,
SFO ,
Spoofing ,
Tax Fraud ,
Traders ,
UK ,
Unexplained Wealth Orders (UWOs) ,
United Arab Emirates (UAE) ,
Yates Memorandum
This is the second edition of The Distributed Ledger, a periodic publication covering the latest trends and developments in blockchain technology, digital assets and smart contracts. In this issue, we examine the SEC’s new...more
11/8/2018
/ Anti-Money Laundering ,
Blockchain ,
CFTC ,
CNIL ,
Commodity Exchange Act (CEA) ,
Cross-Border Transactions ,
Data Controller ,
Data Processors ,
Digital Assets ,
EU ,
FATF ,
FinHub ,
FinTech ,
Initial Coin Offering (ICOs) ,
International Data Transfers ,
Personally Identifiable Information ,
Popular ,
Regulatory Agenda ,
Securities and Exchange Commission (SEC) ,
Smart Contracts ,
Startups ,
Terrorist Financing Regulations ,
Virtual Currency
This issue of Skadden’s semiannual Cross-Border Investigations Update takes a close look at recent cases, regulatory activity and other key developments, including the use of legal holds in cross-border investigations,...more
8/29/2018
/ China ,
Civil Monetary Penalty ,
Cooperation ,
Criminal Investigations ,
Cross-Border Transactions ,
Cryptocurrency ,
Cybersecurity ,
Data Breach ,
Data Protection ,
Department of Justice (DOJ) ,
Enforcement Actions ,
EU ,
Fee Reductions ,
General Data Protection Regulation (GDPR) ,
Initial Coin Offering (ICOs) ,
Personal Liability ,
Popular ,
Privileged Communication ,
Serious Fraud Office (SFO) ,
Settlement ,
Trump Administration ,
UK
On May 8, 2018, President Donald Trump announced that the United States was withdrawing from its participation in the Joint Comprehensive Plan of Action (JCPOA), the agreement the P5+1 (the United States, China, France,...more
5/15/2018
/ Economic Sanctions ,
EU ,
General Licenses ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Presidential Memorandum ,
Rescission ,
SDN List ,
Secondary Sanctions ,
Trump Administration ,
Winding Down
In the wake of the Panama Papers controversy, the U.S. government has taken major steps this month to promote financial transparency. First, the Financial Crimes Enforcement Network (FinCEN) finalized its proposed rule issued...more
5/17/2016
/ Anti-Money Laundering ,
Banks ,
Customer Due Diligence (CDD) ,
Due Diligence ,
Economic Sanctions ,
EU ,
Financial Institutions ,
FinCEN ,
Office of Foreign Assets Control (OFAC) ,
Ownership Requirements ,
Popular ,
Transparency ,
White Collar Crimes
On January 16, 2016, the International Atomic Energy Agency verified that Iran had complied with the nuclear-related technical aspects of the Joint Comprehensive Plan of Action it had to complete before the first phase of...more
1/28/2016
/ Banking Sector ,
Economic Sanctions ,
EU ,
Foreign Entities ,
IAEA ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Nuclear Weapons ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
SDN List
Editor’s note: This article was updated on July 23, 2015, to Editor’s note: This article was updated on July 23, 2015, to reflect certain additional information in U.N. Security Council Resolution 2231.
On July 14, 2015,...more
7/21/2015
/ Aircraft ,
Aircraft Equipment ,
Automotive Industry ,
Banks ,
Crude Oil ,
Energy Sector ,
EU ,
Financial Institutions ,
Implementation Day ,
Imports ,
International Atomic Energy Agency ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Metals ,
Non-US Entities ,
Nuclear Power ,
Nuclear Weapons ,
Office of Foreign Assets Control (OFAC) ,
P5+1 Nations ,
SDN List ,
Shipping ,
Software ,
Transition Day ,
United Nations
Since the outbreak of the Ukraine crisis, the United States and the European Union have sought to align their sanctions responses against Russia. Indeed, this trans-Atlantic bid to leverage economic costs on Russia in...more