In the context of the third anniversary of Russia’s invasion of Ukraine, the U.S., EU, and U.K. continue to implement new measures to stifle Russia’s war efforts. The Biden administration continued to escalate sanctions...more
Did you know that whistleblowers can use the False Claims Act to get the U.S. Government to investigate allegations of lost revenue to the U.S. Treasury, including underpaid Customs tariffs? A large importer recently found...more
On August 8, 2023, the Department of the Treasury's Office of Foreign Assets Control (OFAC) issued General License 13F Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024...more
This update addresses the full implementation of the price cap policy for crude oil and petroleum products of Russian origin by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). On Feb. 3, OFAC...more
In response to the Russian Federation’s (Russia) egregious and unprovoked invasion of Ukraine that began in February 2022, the U.S. government has deployed a whole-of-government approach in imposing sanctions and export...more
Ensuring compliance is key for an organization’s success. The ongoing conflict in Ukraine is a salient reminder that the world shifts on its axis from time to time, and many of our working assumptions have to go by the...more
Now that the United States and its allies have deployed many of their available financial and trade weapons in support of Ukraine against Russia's invasion, what happens next? Perhaps more than any other U.S. sanctions...more
In response to a variety of activities allegedly undertaken by Russia, the U.S. Government has imposed a series of additional sanctions and export control measures since early March. Collectively, the March and April...more
In March 2021, three federal agencies promulgated international trade restraints as part of the Biden Administration’s response to alleged mistreatment of Russian opposition leader Alexey Navalny in 2020. Specifically, the...more
The still evolving US sanctions (as well as the EU and now also separate UK sanctions) continue to challenge Russia-related business. The sanctions frameworks are complex, changing, and, at times, inconsistent as well as...more
There’s been a non-stop bombardment of recent export amendments involving China and other “countries of concern” within the last six months. The main driver behind these has been the U.S. Government’s concern about the...more
On 2 March 2021, the United States and European Union ("EU") imposed coordinated sanctions in response to the poisoning and imprisonment of Russian opposition politician Aleksey Navalny (and the related US determination that...more
Turning to the business of exports from the United States, the next section is a must-read for any company doing business in the United States or from the United States. Or for that matter, any company competing with affected...more
On December 14, 2020, the United States (US) imposed sanctions on Turkey pursuant to Countering America’s Adversaries Through Sanctions Act (CAATSA) for “knowingly engaging in a significant transaction with Rosoboronexport...more
United States - Various threats of further broad sanctions… triggered by ongoing negative developments and perceptions in the US-Russia relationship – though new sanctions legislation seems unlikely before the 3 Nov. US...more
This presentation, an update to our April 2020 presentation, highlights the most recent developments and then provides a detailed overview of the relevant frameworks and their possible implications—including a focus on the...more
Earlier this week, on July 15, 2020, U.S. Secretary of State Mike Pompeo paved the way for enhanced sanctions on the Russian Nord Stream 2 and TurkStream projects by announcing that the Trump Administration is removing an...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
On December 20, 2019, President Trump signed into law the National Defense Authorization Act for Fiscal Year 2020 (“NDAA 2020”), which includes numerous sanctions-related provisions. The law includes the previously introduced...more
The following is Part II of this article. Secondary Sanctions – Requirements On Non-U.S. Parties That Have No Contacts With the U.S. OFAC also has adopted sanctions that specifically apply to non-U.S. companies and...more
Last Wednesday, February 13, a bipartisan group of senators sent Presidents Trump and Putin a Valentine's Eve present by reintroducing a revised Defending American Security from Kremlin Aggression Act, or “DASKA” – a tough...more
On Sunday, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced that it lifted sanctions on three entities associated with Russian oligarch Oleg Deripaska, including the second-largest aluminum...more
On December 19, 2018, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) notified Congress of its intent to remove UC Rusal plc (“Rusal”), the major Russian aluminum producer, and two other...more
Happy new year everyone. The government is shut down, but there has already been a flurry of activity in 2019 on the economic sanctions and embargoes front. Here is a summary of where we stand on various sanctions regimes....more
On 19 December 2018, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) submitted a notification to Congress that it plans to terminate sanctions on three major companies originally designated for...more