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Mexican Companies Face Risk of Secondary Sanctions From Mexican President’s Offer to Sell Gasoline to Venezuela

Mexican President Andrés Manuel López Obrador recently announced that Mexico is willing to ship gasoline to Venezuela notwithstanding the threat of US sanctions against such activity. ...more

US Persons Must Report Transactions Involving Three Previously Sanctioned Russian Entities by February 11

US persons who have engaged in wind-down or maintenance transactions with EN+ Group, UC Rusal, or JSC EuroSibEnergo (or entities they own or control) pursuant to General License 14E or 16E must report those transactions to...more

New US Sanctions Against Russia Create Unique Issues for Fund Investors

The Office of Foreign Assets Control recently designated 7 “oligarchs,” 17 government officials, 13 companies, and one bank, all Russian, as Specially Designated Nationals (SDNs), effectively prohibiting US persons...more

New Russia Sanctions: Key Takeaways

The new sanctions fall within the framework of existing US sanctions against Russia, but have expanded their application by classifying new, prominent individuals and companies as “Specially Designated Nationals.” Given the...more

Federal Criminal Case Raises Provocative Questions on US Jurisdiction

Can the US government criminally prosecute non-US persons for activities that constitute secondary Iranian sanctions violations with no alleged nexus to the United States?...more

Implications Arising from the Recent Venezuelan Sanctions

Though intended to avoid stifling trade in existing Venezuelan government bonds, the sanctions include restrictions on dealings in certain bonds that could impact bond holders....more

US President Issues Executive Order Imposing Additional Sanctions on North Korea

The executive order expands the extraterritorial reach of existing North Korea sanctions by extending it to US persons’ dealings with non-US actors that do business with North Korea....more

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