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
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
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
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
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
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