Archives: Economic Sanctions

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UN and EU North Korea Sanctions: Impacts on European and Cross-Border Trade

As tensions continue to escalate between the United States and North Korea, and President Donald Trump and Kim Jong-Un trade increasingly tense lobs, the United Nations, the EU, the United States, and other countries continue to impose further stringent sanctions against North Korea to a breaking point (for details on UN Security Council Resolution 2375 … Continue Reading

A ‘Modest Proposal’ for Cuba: OFAC, BIS and State Department Implement President’s New Cuba Policy

Effective November 9, 2017, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Department of Commerce’s Bureau of Industry and Security (BIS) amended the Cuban Assets Control Regulations (CACR) and Export Administration Regulations (EAR), respectively, to implement US Cuba sanctions policy changes President Trump announced in a presidential memorandum issued June … Continue Reading

Russian Sanctions Update: OFAC Amends Directive 4 and Updates FAQ Guidance

On October 31, 2017, the Office of Foreign Assets Control (OFAC) took a number of actions to implement the Countering Russian Influence in Europe and Eurasia Act (CRIEEA) (also known as the Countering America’s Adversaries Through Sanctions Act (CAATSA), a larger sanctions statute of which CRIEEA was a part).  As part of this, OFAC amended Directive … Continue Reading

Economic Sanctions Webinar

On Wednesday, November 15 at 12:00 PM EST, Anthony Rapa will be presenting “Recent Developments in Economic Sanctions: Russia, Iran, Venezuela, North Korea, and Cuba,” a webinar hosted by Federal Publications.  As described on the Federal Publications website: From “decertifying” the Iran deal to disputes with “Rocket Man,” the economic sanctions world has seen dizzying … Continue Reading

State Department Allows Certain Civilian Trade to Continue with Russia’s Defense Sector

On October 27, 2017, the US Department of State, pursuant to Section 231 of the Countering America’s Adversaries Through Sanctions Act (CAATSA), published the list of entities that are part of, or operate for or on behalf of, the Russian defense or intelligence sectors, as well as Guidance that sets out indicators of how the … Continue Reading

Congress Continues Bipartisan Focus on Sanctions Legislation

The House of Representatives was the scene of a flurry of sanctions-related activity this week, as the lower chamber passed new sanctions measures related to North Korea, Iran, and Hizballah. The bipartisan consensus on sanctions policy in the House continued, with three of the bills passing by unanimous voice vote and the other two bills … Continue Reading

OFAC Continues Belarus Sanctions Relief

On October 24, 2017, the US Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued a general license continuing the extension of certain sanctions relief toward Belarus. The general license, which is the fourth in a series of identical licenses, authorizes US persons to engage in certain transactions with nine Belarus-based entities that have … Continue Reading

President Trump Decertifies Iran Deal, Outlines New Approach

As a follow up to our recent blog post, Steptoe published a detailed advisory on President’s Trump’s October 13, 2017 announcement that his administration would take a new strategic approach with regard to Iran and that he “cannot and will not” continue to make at least one of the periodic certifications regarding the Joint Comprehensive … Continue Reading

President Trump Outlines New Strategic Approach Regarding Iran

In a speech today, President Trump announced the result of his Administration’s strategic review of foreign policy towards Iran, including the Joint Comprehensive Plan of Action (“JCPOA”) implemented by the Obama administration in January 2016.  As set out in a White House fact sheet, the Trump Administration will seek to expand the focus of U.S. … Continue Reading

Trump Administration Announces Permanent Rollback of Sudanese Sanctions Regulations

On October 6, the U.S. Government announced the termination of U.S. sanctions against Sudan, which had been in place since 1997. While most of the recent developments regarding U.S. sanctions have involved increasing sanctions against countries such as North Korea and Venezuela, Sudan-related sanctions policy has been quietly moving in the opposite direction, with the … Continue Reading

Bank Warranties: The Other Sanctions Regulations

Imagine, for a moment, that your company has achieved a state of compliance nirvana. Through the diligent efforts of compliance personnel and counsel, the company has assessed its economic sanctions and export control risks, implemented policies and procedures to prevent unlawful activity, and provided compliance training to employees.  With those measures in place, the company … Continue Reading

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

OFAC Shortens New Debt Maturity Periods under Russian Financial and Energy Sectoral Sanctions

OFAC today revised its Ukraine/Russia-related sectoral sanctions directives prohibiting US person dealings in new debt or new equity of listed Russian financial institutions and new debt of listed Russian energy companies (in both cases, these prohibitions continue to apply to the “interests in property” of the listed entities, meaning any entity 50% or more owned … Continue Reading

OFAC Reaches Settlement Agreement with Richemont North America

On September 26, 2017, the US Office of Foreign Assets Control (OFAC) published information about a civil enforcement action against Richemont North America, d.b.a. Cartier, headquartered in New York.  Richemont agreed to settle charges and pay approximately $334,800 for allegedly selling jewelry to a Specially Designated National and Blocked Person designated under the Foreign Narcotics … Continue Reading

UN and US Impose New Sanctions on North Korea Amidst Increasing Hostility

On September 26, 2017, Steptoe published an advisory on the newest UN and US sanctions on North Korea. As tensions between the United States and North Korea continue to escalate – and President Donald Trump and Kim Jong-Un trade increasingly harsh barbs – the United Nations, United States, and other countries continue to impose tough … Continue Reading

FinCEN, OFAC Increase Coordination of Enforcement Activities

Recent joint activity by the Financial Crimes Enforcement Network (FinCEN) and the Office of Foreign Assets Control (OFAC), including joint actions against Venezuela and North Korea, suggest that the two Treasury agencies are increasing coordination to tackle financial and other crimes. On September 20, 2017, FinCEN issued an advisory which detailed widespread corruption in Venezuela, … Continue Reading

U.S. Cuts off Venezuela from Most Dollar-Denominated Financing

On August 25, the U.S. Government announced the publication of a new Executive Order, signed by President Trump on August 24 and effective at 12:01am on August 25, prohibiting U.S. persons from engaging in any transactions or dealings involving “new” debt of certain maturity durations of the Government of Venezuela (GoV) and Petroleos de Venezuela, … Continue Reading

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
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