Archives: EU Sanctions

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EU Raises Specter of Blocking Regulation as Trump Administration Ponders JCPOA

In a panel hosted by the Atlantic Council last week, the EU Ambassador to the United States, David O’Sullivan, stated that the European Union could block U.S. sanctions on Iran if the United States pulls out of the Joint Comprehensive Plan of Action (“JCPOA”). The U.S. Congress built in a requirement under the Iran Nuclear Agreement Review … Continue Reading

European Commission Proposes EU-Wide Scheme for Screening Foreign Investments in the EU

The European Commission issued on September 13th 2017 a Proposal for a Regulation establishing a framework on the screening of foreign direct investments (FDI) into the EU. The objective of this proposal is two-fold: pushing third countries to open their domestic markets to EU investments, and protecting EU assets against foreign takeovers detrimental to the … 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

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a press release, regulations regarding civil penalties, responses received to OFSI’s request for consultation regarding draft guidance issued in December … Continue Reading

UK to Move Towards US-Style Sanctions Enforcement with Upcoming Penalty Regulations

The UK’s Office of Financial Sanctions Implementation will soon issue regulations that could significantly alter the British sanctions enforcement environment, and bring it closer in line with the US’s approach to such violations.  On the heels of the newly-enacted Policing and Crime Act 2017, the regulations will introduce civil penalties for the violation of financial … Continue Reading

Non-Member States Align with EU on Russia Sanctions Extension

On October 24, the EU announced that Liechtenstein, Norway, Montenegro, Albania, and Ukraine would renew sanctions against Russia in alignment with current EU policy.  As we have previously discussed, the EU prolonged restrictive measures against Russia in September, after determining that the situation in Ukraine did not merit a change in sanctions policy.  The asset … Continue Reading

How the 2016 Election Will Impact Public Policy Developments

Sunday’s presidential town hall debate was the second of three opportunities for candidates Donald Trump and Hillary Clinton to make their case to the American electorate.  In addition to the discussion of personal and character issues, the candidates touched on a range of policy issues, including tax policy, financial services, energy, and international trade.  The … Continue Reading

EU Prolongs Sanctions Over Actions Against Ukraine’s Territorial Integrity

The Council of the European Union has decided to prolong by 6 months the application of EU restrictive measures targeting actions against Ukraine’s territorial integrity, sovereignty and independence. These sanctions consist of an asset freeze and a travel ban against 146 persons and 37 entities.  They have been extended until 15 March 2017. The measures … Continue Reading

EU Extends Russia Sanctions Through January 2017

The EU has extended, today, economic sanctions targeting specific sectors of the Russian economy to 31 January 2017.  The extension is set out in Council Decision (CFSP) 2016/1071. The sanctions concern the financial, energy and defence sectors, as well as dual-use goods, and have been extended because the Council has assessed that the Minsk agreements … Continue Reading

French Senate Overwhelmingly Votes to Roll Back Russia Sanctions

Yesterday, the French Senate voted 302-16 to “gradually and partially” lift sanctions on Russia, despite opposition from the Hollande government.  While this vote has no legal effect, it was a strong showing of political opposition in France to the continuing EU sanctions.  The US and EU have largely remained aligned on their policy that Russia … Continue Reading

UK Government Proposes Increased Penalties for Sanctions Violations

On February 10, 2016, a draft of the Policing and Crime Bill 2015-16 (“the Bill”) was introduced to the UK House of Commons and given its First Reading.  The Bill is a lengthy document covering a wide variety of issues, including financial sanctions, which are contained within Part 8. Alongside the Bill, the UK government … Continue Reading

EU Ending Most Sanctions Against Belarus – Will the US follow?

According to a February 15, 2016 announcement, the Council of the European Union has decided to permanently end certain sanctions against Belarus. The EU will lift measures that froze the assets of individuals and entities connected to the regime of Alexander Lukashenko. An arms embargo and sanctions on persons closely linked to the disappearance of … Continue Reading

US, EU Implement Iran Sanctions Relief

The Joint Comprehensive Plan of Action between Iran and six world powers became effective on January 16, 2016 (“Implementation Day”), triggering significant sanctions relief in exchange for Iran curtailing its nuclear program.  While the EU has lifted most of its sanctions against Iran and the US has also eased a broad range of sanctions applicable … Continue Reading

US, EU Implement JCPOA Iran Sanctions Relief

Today, the International Atomic Energy Agency (“IAEA”) announced that Iran has met the first round of its nuclear-related commitments under the Joint Comprehensive Plan of Action (“JCPOA”).  As Steptoe explained when the JCPOA was agreed to between Iran and the P5+1 countries in July 2015, Iran would not receive any sanctions relief until “Implementation Day,” the … Continue Reading

OFAC Issues General License Authorizing Transactions with Certain Belarusian SDNs, EU Suspends Belarus Sanctions for Four Months

Today, OFAC issued a general license authorizing U.S. persons to engage in transactions with certain Belarus-based companies that have been designated as Specially Designated Nationals (SDNs).  Specifically, the general license authorizes transactions with the following companies: Belarusian Oil Trade House Belneftekhim Belneftekhim USA, Inc. Belshina OAO Grodno Azot OAO Grodno Khimvolokno OAO Lakokraska OAO Naftan OAO … Continue Reading

Implications for the Insurance, Reinsurance, and Brokerage Industry Under the JCPOA

Steptoe’s Guy Soussan and Jack Hayes recently published an article in Insurance Day about the implications for the insurance, reinsurance, and brokerage industry under the Joint Comprehensive Plan of Action (JCPOA) related to Iran.  There are five key points: Virtually all EU insurance-related sanctions would be removed. Some, but not all, US insurance-related sanctions would … Continue Reading
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