Archives: Economic Sanctions

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A Detailed Look at the Countering America’s Adversaries Through Sanctions Act

President Trump signed the Countering America’s Adversaries Through Sanctions Act into law on August 2, 2017, targeting Russia, North Korea, and Iran.  The law serves as a forceful, bipartisan statement that the US Congress continues to view robust economic sanctions as a foundation of US foreign policy, in which Congress will play a leading role … Continue Reading

Significant FinCEN Action Against BTC-e, Implications for Virtual Currency Exchangers

The US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) assessed a civil monetary penalty of $110,003,314 against Canton Business Corporation (BTC-e) as well as a $12,000,000 penalty against Alexander Vinnik on July 26, 2017.  BTC-e is one of the largest virtual currency exchanges by volume in the world and Vinnik is a Russian … Continue Reading

UPDATE: Congress Passes Sweeping Iran, Russia, and North Korea Sanctions Legislation

On July 27, the Senate passed 98-2 the Countering America’s Adversaries Through Sanctions Act (HR 3364), which previously passed the House 419-3 on July 25, setting up  a showdown with President Trump. This bill is an omnibus of three separate sanctions measures: the Countering Iran’s Destabilizing Activities Act (“CIDAA”), the Countering Russian Influence in Europe … Continue Reading

Lawsuits for Cuban Confiscated Property Still Suspended, For Now

On Friday, July 14, 2017, the Trump administration joined the administrations of Presidents Clinton, Bush, and Obama in suspending Title III of the Cuban Liberty and Democratic Solidarity (LIBERTAD) Act of 1996, also known as the Helms-Burton Act, a controversial provision that would authorize lawsuits in U.S. courts to recover damages related to confiscated property … Continue Reading

Trump Administration Recertifies Iran’s Compliance with Nuclear Deal, Imposes Sanctions on IRGC-Linked Individuals and Entities

The Iran nuclear deal lives to see another day—but President Trump continues to express deep reservations regarding the agreement. Iran Nuclear Deal Certification On Monday, the Trump Administration reportedly certified Iran’s compliance with its nuclear-related obligations under the Joint Comprehensive Plan of Action (JCPOA) agreement, as required under the Iran Nuclear Agreement Review Act (INARA). … Continue Reading

OFAC Penalizes AIG’s Voluntary Disclosure of Overly “Narrow” Exclusion Clauses and Single Shipment Policies

On June 26, 2017, American International Group, Inc. (AIG) agreed to a $148,698 civil settlement with OFAC based on a voluntary disclosure of 555 apparent violations of OFAC’s Iran, Sudan, Cuba and Weapons of Mass Destruction Proliferators economic sanctions programs.  AIG processed approximately $396,530 in premiums and paid claims on policies covering maritime shipments of … Continue Reading

President Trump Delays Decision on Permanent Rollback of Sudan Sanctions

On July 11, 2017, President Trump issued an executive order (“new executive order”) delaying the Trump Administration’s decision on whether to make permanent broad Sudan sanctions relief instituted in the waning days of the Obama Administration. On January 13, 2017, President Obama issued Executive Order (“EO”) 13761, which waived a number of statutory provisions mandating … Continue Reading

US Ratchets up Pressure on North Korea by Targeting Chinese Supporters

President Trump’s recent exasperated tweet at China – suggesting China is not doing enough to stop North Korea’s nuclear efforts and rogue behavior – was followed last week by financial sanctions on Chinese supporters of North Korea.  On June 29, the Treasury Department’s Office of Foreign Assets Control (“OFAC”) placed on its list of Specially … Continue Reading

Sanctions Round-Up

Sanctions, sanctions, and more sanctions– everyone’s favorite tool of foreign policy sure has been making a lot of news lately.  Here’s a round-up of the latest sanctions analysis here at the International Compliance Blog: Russia: Peter Jeydel summarized the Russia sanctions bill that the Senate passed on June 14, while Alexis Early assessed the bill’s prospect for passage … Continue Reading

Back to the Future on “Extraterritorial” Sanctions on Russian Pipelines?

Earlier this month, after the Senate overwhelmingly passed a bill that would authorize (and in some cases mandate) sanctions on foreign energy firms that participated in certain Russian energy projects, the Governments of Germany and Austria issued a joint statement that they “cannot accept a threat of extraterritorial sanctions, illegal under international laws, against European … Continue Reading

What Can We Say About The Trump Administration’s First Russia Sanctions?

The Treasury Department’s Office of Foreign Assets Control (OFAC) today designated 38 individuals and entities in order to “reinforce[] existing sanctions on Russia.”  This announcement came while President Trump was meeting the President of Ukraine in the White House.  These were the first new sanctions under the Trump Administration related to the conflict in Ukraine … Continue Reading

New Cuba Policy May Not Significantly Impact Many Sectors

President Trump announced, on June 16, 2017, that, “effective immediately, I am canceling the last administration’s completely one-sided deal with Cuba.” However, with two primary exceptions, the Presidential Memorandum setting out the new policy may leave in place most of the steps to ease the embargo that the Obama Administration and previous administrations had taken. … Continue Reading

OFAC Removes Burmese Sanctions Regulations

On June 16, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced that it removed the Burmese Sanctions Regulations (“BSR”) from the Code of Federal Regulations.  This removal is the culmination of actions taken by the Obama Administration in October 2016 to terminate the national emergency with respect to Myanmar (EO … Continue Reading

Cuba Policy Changes Will Complicate New Business But Grandfather Existing Deals

In a much-anticipated speech on Cuba policy today, President Trump announced that, “effective immediately, I am canceling the last administration’s completely one-sided deal with Cuba.” That pronouncement notwithstanding, it appears that the Trump Administration’s new policy on Cuba (as set out in a Presidential Memorandum) will leave intact most of the changes made by the … Continue Reading

Congress Flexes Sanctions Muscles: Bills Target Iran, Russia, and Others

This month, Congress is considering an array of new sanctions-related legislation, and, in recent days, bipartisan support has grown for a bill that would potentially direct significant measures against Russia and Iran. Congress has also debated bills proposing new sanctions against North Korea, Hamas, Hezbollah, and both chambers have put forth multiple bills that would … Continue Reading

Epsilon Electronics: A Cautionary Tale on Transshipments?

On May 26, 2017, in Epsilon Electronics v. US Department of the Treasury, a split panel of the DC Circuit Court of Appeals partially upheld and partially remanded to the district court a determination by the Treasury Department’s Office of Foreign Assets Control (OFAC) to impose a penalty of over $4 million against Epsilon for … Continue Reading

Between a rock and a hard place: How to ensure sanction compliance when operating a facility in a sanctions-targeted country

The recently reported resignation of cement manufacturer LafargeHolcim’s CEO has thrown a spotlight on the risks of operating commercial activities in countries targeted by economic sanctions.[1] Without drawing any conclusions on the legal qualification of LafargeHolcim’s conduct in the specific circumstances, the following provides an overview of the principal issues at stake in this case. … Continue Reading

OFAC Extends Belarus Sanctions Relief

On April 28, 2017, the U.S. Department of Treasury, Office of Foreign Assets Control (“OFAC”) issued a general license extending sanctions relief, which authorizes U.S. persons to engage in certain transactions with nine Belarus-based entities that have been designated as Specially Designated Nationals (“SDNs”), as well as other entities in which the nine entities have … Continue Reading

Trump Administration Uses New Approach in Syria Sanctions Action

On April 24, 2017, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned 271 employees of Syria’s Scientific Studies and Research Center (“SSRC”) pursuant to Executive Order 13582 (targeting the Syrian government and its supporters).  The designations are part of the Trump Administration’s response to the April 4, 2017 chemical weapons … Continue Reading

Trump Administration Certifies Iran’s Compliance with Nuclear Deal, but Initiates Review of Sanctions Relief

Will the Trump Administration “waive” goodbye to sanctions relief under the Iran nuclear deal? Last night, Secretary of State Rex Tillerson certified to Congress that Iran is in compliance with the Joint Comprehensive Plan of Action (JCPOA) agreement regarding Iran’s nuclear program, but signaled that the Trump Administration is reviewing whether continued sanctions relief under the … Continue Reading

What’s in a Photo? And Thoughts on the UK Sanctions Scene

A couple of recent news items throw into sharp relief what we long have noted here at the International Compliance Blog—that economic sanctions are a key tool of a country’s national security and foreign policy, and can serve as an instrument by which to influence a broad array of events. First, take a look at this photo: … Continue Reading

OFSI Issues Regulations Implementing Civil Penalties for Financial Sanctions Violations

Following up on our previous post, yesterday the UK Office of Financial Sanctions Implementation (OFSI) issued regulations formally implementing the civil penalties framework set out in the Policing and Crime Act 2017.  OFSI has issued a press release, regulations regarding civil penalties, responses received to OFSI’s request for consultation regarding draft guidance issued in December … Continue Reading
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