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OFAC Issues Venezuela Sanctions Regulations

On July 10, 2015, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published, in abbreviated form, Venezuela Sanctions Regulations (VSR) in 31 C.F.R. Part 591. The VSR implement the Venezuela...more

Pushing Deadline for Iran Nuclear Deal, Negotiators Extend Temporary Sanctions Relief for Seven Days

As nuclear negotiations in Vienna reach the targeted June 30, 2015, deadline for an agreement, the P5+1, EU and Iran agreed today to extend the limited and temporary sanctions relief to Iran through July 7, 2015. The...more

EU Extends Current Sanctions Against Russia and Crimea

Signaling increased tensions with Russia regarding its alleged intervention in eastern Ukraine, the European Union on June 19 and 22, 2015, took action extending sanctions targeting Russia and Crimea, including measures that...more

6/29/2015  /  Crimea , EU , Russia , Sanctions , Ukraine

U.S. Government and Fokker Appeal District Court’s Rejection of Deferred Prosecution Agreement

On June 8, attorneys for the U.S. Department of Justice (DOJ) joined Dutch aerospace company Fokker Services BV (“Fokker”) in appealing the district court’s rejection of Fokker’s deferred prosecution agreement (DPA) with the...more

FinCEN Seeks to Curb Trade-Based Money Laundering Through Lowered Reporting Threshold

On April 21, 2015, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued a Geographic Targeting Order (“GTO”) lowering reporting thresholds and triggering additional recordkeeping requirements...more

President to Remove Cuba’s Terrorism Designation: Most Sanctions Remain in Effect

On April 14, President Obama notified Congress of his intent to rescind Cuba’s designation as a State Sponsor of Terrorism (SSOT), issued in March 1982, saying the Cuban government “has not provided any support for...more

Negotiators Agree on Iran Deal Framework Providing Basis for Limited Easing of Sanctions

Thursday, negotiators from the United States, Iran and other world powers announced they have agreed on a framework for a Joint Comprehensive Plan of Action regarding Iran’s nuclear program to be finalized by June 30, 2015....more

Obama Signs Executive Order Establishing Cybersecurity Sanctions Regime

On April 1, 2015, President Obama signed an executive order establishing a new sanctions program targeting individuals and entities responsible for, or complicit in, cyber-enabled activities that threaten the national...more

U.S. Implements Targeted Sanctions on Venezuela

On March 9, 2015, following failed diplomatic efforts to bring Venezuela in line with its human rights commitments under international law, President Obama issued an Executive Order (E.O.) declaring Venezuela a national...more

DOE Overhauls Export Controls for Nuclear Technology

On February 23, 2015, the Department of Energy (DOE) released a long-awaited final rule overhauling its Part 810 Regulations (10 C.F.R. Part 810) governing the export of certain nuclear technology and assistance. Effective on...more

Obama Administration Loosens Restrictions on Cuba Travel and Commerce

On January 15, 2015, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) and the U.S. Department of Commerce, Bureau of Industry and Security (BIS) released regulatory amendments implementing the Cuba...more

Obama to Sign Venezuela Sanctions Bill

Last week, the U.S. Congress passed S. 2142 (the “Venezuela Defense of Human Rights and Civil Society Act of 2014”) and presented the legislation to President Obama for signature. White House officials have indicated that...more

12/19/2014  /  Barack Obama , Sanctions , Venezuela

U.S. Congress Passes Russia Sanctions Legislation

On Saturday, the U.S. Congress passed the Ukraine Freedom Support Act of 2014 (H.R. 5859), which, once signed by the president, will impose or authorize broad sanctions on Russia’s energy and defense sectors and increase...more

OFAC Clarifies Treatment of Deferred Payments, Oil and Gas “Production,” and Artic Offshore Projects Under Russia Sanctions Regime...

On December 11, 2014, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) released new guidance related to existing U.S. sanctions against Russian entities designated on the Sectoral Sanctions...more

New Sanctions Guidance Increases Due Diligence Burden on Companies

On August 13, 2014, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) published guidance (“Revised Guidance”) that revises its 2008 guidance regarding how to treat entities that are owned or...more

United States and European Union Impose Broad Economic Sanctions Against Russia

On July 29, 2014, the United States and the European Union (EU) announced a significant expansion of sanctions against Russia in response to its continued support of separatists in eastern Ukraine. The measures introduced by...more

7/31/2014  /  EU , Foreign Policy , Russia , Sanctions , Ukraine

African Growth and Opportunity Act, Electrify Africa Act and Power Africa Program to Take Center Stage at U.S.-Africa Leaders...

From August 4-6, President Obama will host approximately 45 leaders from across the African continent in Washington, D.C., for a three-day U.S.-Africa Leaders Summit (the “Summit”). This is the first such event of its kind...more

Court Orders CFIUS to Increase Transparency but Rejects Review of Presidential Determination

A recent decision by the D.C. Circuit has prompted much speculation about possible changes to the traditionally opaque and secretive national security review process administered by the Committee on Foreign Investment in the...more

Obama Administration Imposes New Sanctions on Key Russian Energy, Financial and Defense Companies; EU Considering Expanded...

The Obama Administration announced new sanctions on Wednesday, July 17, 2014, targeting key companies in Russia’s energy, financial and defense sectors, as well as other companies, regional separatist governments, and...more

Ukraine-Related Sanctions Regulations: An Update

On May 8, 2014, the Office of Foreign Assets Control (“OFAC”) issued the Ukraine-Related Sanctions Regulations (“URSR”), 31 C.F.R. Part 589. The URSR implement the sanctions set forth in Executive Orders 13660, 13661, and...more

5/21/2014  /  Foreign Policy , Russia , Sanctions , Ukraine

EU, U.S., Ukraine and Russia Sign Pact to Deescalate Crisis, but Sanctions Threats Still Loom

On April 17, 2014, U.S., EU, Russian and Ukrainian representatives endorsed an agreement outlining initial steps to deescalate tensions in Ukraine. For the moment, the agreement may temporarily stall additional U.S. and EU...more

4/22/2014  /  EU , Foreign Policy , Russia , Sanctions , Ukraine , US

President Obama Signs Ukraine Bill Into Law

On April 3, 2014, President Obama signed into law the Support for the Sovereignty, Integrity, Democracy, and Economic Stability of Ukraine Act of 2014 (Public Law No. 113-95). The law includes new authority, not specifically...more

4/8/2014  /  Barack Obama , Russia , Sanctions , Ukraine

Certain Trade with Russia on Hold

The Obama administration announced this week that companies with pending license requests to export certain controlled dual-use goods or technology, defense articles or defense services to Russia will face an indefinite hold...more

Sanctions Relating to Situation in Ukraine: An Overview of Recent Developments

The ongoing conflict between Russia and Ukraine has led to recent changes in sanctions laws that have significance for U.S., European Union (EU) and Russian companies as well as companies that do business within these...more

3/25/2014  /  EU , Sanctions , Ukraine

New Item for Diligence Review Process: OFAC’s Foreign Sanctions Evaders List

On February 6, 2014, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) published notice that it was listing 11 named parties as “Foreign Sanctions Evaders,” pursuant to Executive Order 13608 (May 1, 2012)...more

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