The U.S. Government is continuing to implement measures under U.S. export controls and economic sanctions in response to China’s recent actions involving Hong Kong, including China’s enactment of a new national security law...more
As we discussed in our last alert, Congress has exhibited increased willingness to consider imposing sanctions in order to advance US foreign policy interests. Multiple sanctions-related bills are currently under...more
The new Iran sanctions imposed by the Trump Administration are not the only recent sanctions actions of note. Congress has also shown its willingness to use sanctions as a foreign policy tool, with certain sanctions...more
1/23/2020
/ Asset Freeze ,
Blocking Sanctions ,
Congressional Committees ,
Defense Sector ,
Drug Trafficking ,
Economic Sanctions ,
Iran ,
Iran Sanctions ,
NDAA ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Opioid ,
Pipelines ,
Procurement Guidelines ,
Syria ,
Venezuela
On January 10, 2020, the US Administration announced the imposition of new sanctions against Iran. The sanctions were initially announced in President Trump’s public address on January 8, 2020, in the aftermath of Iran’s...more
On December 13, 2019, the US Department of Justice (DOJ) issued an update to its 2016 guidance regarding enforcement in export control and sanctions investigations of businesses. The updated policy now offers voluntary...more
12/20/2019
/ Compliance ,
Cooperation ,
Criminal Investigations ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Export Controls ,
Financial Institutions ,
Government Investigations ,
Guidance Update ,
National Security ,
Remediation ,
Terrorism Funding ,
Voluntary Disclosure
In a show of support for Venezuelan Interim President Juan Guaidó last week, and in opposition to the Maduro regime, President Trump issued Executive Order 13884, which imposes blocking sanctions on the Government of...more
The Trump Administration announced last week that the US Government has added Huawei to the Commerce Department Entity List and, as of May 20, 2019, has announced a temporary general license for certain transactions. Here is...more
5/22/2019
/ China ,
Economic Sanctions ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Huawei ,
Licensing Rules ,
National Security ,
Supply Chain ,
Telecommunications ,
Trump Administration ,
U.S. Commerce Department
How should we approach competing sanctions risks?
Among the numerous regulatory compliance risks faced by financial institutions, economic and trade sanctions risks commonly receive a great deal of attention....more
4/8/2019
/ Blocking Statutes ,
CAATSA ,
Criminal Liability ,
Criminal Prosecution ,
Cuba ,
Economic Sanctions ,
Enforcement Actions ,
EU ,
Financial Institutions ,
Foreign Financial Institutions (FFI) ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
SDN List
Effective October 12, 2017, the U.S. Government has revoked its sanctions against Sudan that were established in Executive Orders 13067 and 13412 and removed a number of Sudanese entities from the SDN List. The revocation...more
On September 20, 2017, President Trump issued Executive Order 13810 setting forth measures intended to further isolate North Korea through the imposition of additional sanctions on North Korean persons and on persons doing...more
President Trump signed into law the Countering America’s Adversaries Through Sanctions Act (the CAATS Act) on August 2, 2017. The CAATS Act impacts sanctions related to Russia, Iran and North Korea....more
Catching many by surprise, President Obama issued an Executive Order on Friday, January 13, 2017, which provides for the lifting of sanctions against Sudan in six months. In addition, OFAC published on Tuesday (January 17,...more