On June 10, 2021, the People’s Republic of China adopted the Anti-Foreign Sanctions Law (the “Law”). The main purpose of the Law is to provide a legal basis for China to adopt retaliatory measures against any so-called “discriminatorily restrictive measures” that may be imposed by foreign countries against Chinese organizations and citizens (the “Foreign Sanctions”).… Continue Reading
On June 3, 2021, US President Joseph Biden issued Executive Order 14032, “Addressing the Threat From Securities Investments that Finance Certain Companies of the People’s Republic of China” (EO 14032), substantially amending the prohibitions originally contained in Executive Order 13959 (EO 13959), issued by President Trump on November 12, 2020 (amended January 13, 2021).… Continue Reading
On April 15, 2021, the US announced a marked expansion of sanctions against Russia and President Biden issued a new Executive Order authorizing the imposition of yet more sanctions. The sanctions include restrictions on certain transactions involving Russian sovereign debt, as well as the designation of 46 individuals and entities implicated in Russia’s annexation of Crimea, foreign … Continue Reading
PT Bukit Muria Jaya (“BMJ”), a global supplier of cigarettes, has agreed to pay a fine of more than $1.5 million and to enter into a deferred prosecution agreement with the Department of Justice (DOJ) for conspiracy to commit bank fraud in connection with the shipment of products to North Korean customers.… Continue Reading
In early October, OFAC announced a US$2,718,581 settlement with The General Electric Company (GE) of Boston, Massachusetts. GE, on behalf of three GE subsidiaries, Getsco Technical Services Inc., Bentley Nevada and GE Betz (collectively, the “GE Companies”), agreed to settle its potential civil liability for 289 alleged violations of the Cuban Assets Control Regulations (CACR). Specifically, between December 2010 and February … Continue Reading
Responding to Turkey’s actions in Syria, President Trump issued an Executive Order (EO) blocking property and suspending entry of certain persons contributing to the situation in Syria. Pursuant to the EO, OFAC added three Turkish government officials and two Turkish government agencies, the Ministry of National Defence and the Ministry of Energy and Natural Resources, to the Specially Designated Nationals (SDN) … Continue Reading
On October 22, 2019, OFAC issued General License No. 2G – General License with Respect to Entities Blocked Pursuant to Executive Order 13405, extending the expiration date of the general license to April 26, 2021. General License No. 2G replaces General License No. 2F and authorizes transactions with blocked entities by Belerusian Oil Trade House, Belneftekhim, Belneftekhim USA, Inc., Belshina OAO, … Continue Reading
Recently, the Department of the Treasury’s OFAC issued an amended General License 8D, “Authorizing Transactions Involving Petróleos de Venezuela, S.A. (PdVSA) Necessary for Maintenance of operations for Certain Entities in Venezuela.”… Continue Reading
On September 4, 2019, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) published in the Federal Register a new final rule on the Nicaragua Sanctions Regulations, 31 C.F.R. Part 582 (Nicaragua Regulations), which implement Executive Order (EO) 13851 of November 27, 2018, “Blocking Property of Certain Persons Contributing to the Situation in Nicaragua”. The Nicaragua Regulations mirror the substance … Continue Reading
The Trump Administration issued an Executive Order (EO) on October 14, 2019, that authorized US Department of the Treasury (Treasury) and US Department of State to impose sanctions on various Turkish individuals and entities involved in the conflict in Northern Syria. The same day that the EO was issued, Treasury’s Office of Foreign Assets Control (OFAC) designated three individuals and two entities as … Continue Reading
On August 5, 2019, President Trump signed a new Venezuela-related Executive Order (EO), which imposes additional sanctions on the government of Venezuela. … Continue Reading
On June 13, 2019, the US Treasury Department’s Office of Foreign Assets Control (OFAC) announced settlements with three travel companies – Expedia Group, Inc. (Expedia), Hotelbeds USA, Inc. (Hotelbeds USA) and Cubasphere Inc. (Cubasphere) – for their alleged involvement in booking travel to Cuba or arranging trips for Cuban nationals between 2011 and 2014.… Continue Reading
On June 24, 2019, the US Department of Commerce, Bureau of Industry and Security (BIS) published in the Federal Register a Final Rule designating five entities, all located in China, to the Entity List. The five entities are: Chengdu Haiguang Integrated Circuit – aliases include Hygon and Chengdu Haiguang Jincheng Dianlu Sheji Chengdu Haiguang Microelectronics Technology – aliases include HMC … Continue Reading
Russian Counter-sanctions: Bill Introduced to Criminalize Dissemination of Information That May Result in Introduction or Expansion of Sanctions Against Russian Persons Following our recent webinar, our Moscow Team prepared an analysis of a draft Russian legislation that would prohibit media communications that reveal non-compliance with sanctions or facilitate imposition of sanctions and would also impose criminal … Continue Reading
On May 21, 2019 the US Commerce Department, Bureau of Industry and Security (BIS) is expected to publish in the Federal Register a Final Rule designating Huawei Technologies Co., Ltd. (Huawei) and 68 affiliated Huawei entities located in 26 countries (collectively, the “Huawei Listed Companies”) to the Entity List. … Continue Reading
On May 2, 2019, the US Department of Treasury’s Office of Foreign Assets Control (OFAC) released guidance on effective sanctions compliance programs. While this is the first document of this kind from OFAC, similar guidance documents by the US Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) have been on the books … Continue Reading
On March 14, 2019, the Department of Treasury’s Office of Foreign Assets Control (OFAC) announced the creation of a new list specifically sanctioning foreign financial institutions (FFIs).… Continue Reading
On January 31, 2019, the Department of Treasury’s Office of Foreign Assets Control (OFAC) announced that it has reached a settlement agreement with e.l.f. Cosmetics, Inc. in the amount of US$996,080 for potential civil liability relating to 156 apparent violations of North Korea Sanctions Regulations. The potential violations stem from importation of false eyelash kits from the People’s Republic of … Continue Reading
On January 28, 2019, the Department of Treasury’s Office of Foreign Assets Control (OFAC) announced that it has designated Petroleos de Venezuela, S.A. (PdVSA) following Executive Order (E.O.) 13850, after a determination by Treasury Secretary Steven T. Mnuchin and Secretary of State Michael Pompeo that PdVSA was operating in the Venezuelan oil sector. Additionally, OFAC has amended General License 3 and … Continue Reading
On January 27, 2019, the Department of Treasury’s Office of Foreign Assets Control (OFAC) announced that it has removed from its Specially Designated Nationals and Blocked Persons (SDN) list certain information for EN+ Group PLC, JSC Eurosibenergo and United Company RUSAL PLC.… Continue Reading
On January 24, 2019, the Department of Treasury’s Office of Foreign Assets Control (OFAC) announced that it has added several individuals and aircraft to its Specially Designated Nationals and Blocked Persons (SDN) list. It also updated information relating to the Islamic Revolutionary Guard Corps.… Continue Reading
On January 16, 2019, the Department of Treasury’s Office of Foreign Assets Control (OFAC) announced that it was extending the expiration dates for the following general licenses related to EN+Group PLC, JSC EuroSibEnergo and United Company RUSAL PLC: General License 13J, General License 14E and General License 16E.… Continue Reading
On January 8, 2019, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela-related General License 6, which authorizes the winding down of certain specified transactions with Globovision Tele C.A. and Globovision Tele CA, Corp. until January 8, 2020. Additionally, OFAC issued new FAQs for General License 6, and also added several new individuals and entities to … Continue Reading
