Archives: Economic Sanctions

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President Trump Issues Venezuela-Related Executive Order

On May 21, 2018, President Trump issued a new executive order prohibiting certain transactions benefitting the government of Venezuela.  The order prohibits all transactions related to, provision of financing for, and other dealings in: (i) the purchase of any debt owed to the Government of Venezuela, including accounts receivable, (ii) any debt owed to the … Continue Reading

In-Depth Advisory on President’s Announcement of Withdrawal From JCPOA and Reimposition of Nuclear-Based Sanctions on Iran

In addition to our previous updates, Steptoe recently published an in-depth advisory on President Trump’s May 8, 2018 decision to withdraw the United States from the Joint Comprehensive Plan of Action (JCPOA). The JCPOA is an agreement reached in July 2015 between Iran, the United States, the United Kingdom, France, China, Russia, and Germany in … Continue Reading

Russia Sanctions: General Licenses, Deadlines, Russian Counter-Measures– What’s the Latest?

As the world turns… There have been several key developments recently in the Russia sanctions context: Issuance of General License 15.  This general license, issued May 22, authorizes maintenance and winding down of pre-April 6 business with GAZ Group and its subsidiaries through October 23.  The authorization is similar in scope to General License 14, issued on … Continue Reading

Russian State Duma Proposes to Criminalize Compliance with US and EU Sanctions and Adopts Retaliatory Measures

On May 14, a cross-party group of Russian lawmakers at the Russian State Duma, the lower house of the Federal Assembly of Russia, introduced an amendment to the Criminal Code of the Russian Federation to create a new offense that would criminalize compliance with US and EU sanctions on Russian soil.  On May 15, the … Continue Reading

OFAC Issues General License Extending Authorization for Dealings with GAZ Group

Yesterday, OFAC issued General License No. 15 under the Ukraine-Related Sanctions Regulations (31 C.F.R. Part 589), authorizing the maintenance or wind-down of pre-April 6 contracts with GAZ Group and its subsidiaries through October 23, 2018.  Previously, such activity with GAZ Group was permitted only through June 5, 2018 as per General License No. 12B (which … Continue Reading

OFAC Eases Maintenance/Wind-Down and Divestment Restrictions in New General Licenses

On May 1, OFAC issued two amended general licenses under the Ukraine-Related Sanctions Regulations (URSR). General License No. 12B, superseding General License No. 12A, authorizes additional activities necessary to the maintenance and winding down of operations or existing contracts. General License No. 13A, superseding General License No. 13, authorizes certain additional transactions necessary to divest … Continue Reading

President Trump Withdraws United States from Iran Nuclear Agreement

Today, President Trump announced “that the United States will withdraw from the Iran nuclear deal” and issued a National Security Presidential Memorandum (NSPM) “to begin reinstating” the “highest level” of economic sanctions on Iran.  Today’s action sets in motion the termination of all or nearly all of the sanctions relief offered by the United States … Continue Reading

OFAC Renews Belarus Sanctions Relief

On April 27, 2018, the U.S. Department of Treasury, Office of Foreign Assets Control (“OFAC”) issued a general license extending sanctions relief that 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 entities that they own 50% or more. The … Continue Reading

OFAC Issues General License Extending Maintenance / Wind-Down Period for Rusal Dealings

On Monday, OFAC issued General License No. 14 under the Ukraine-Related Sanctions Regulations (URSR), authorizing the maintenance or winding down of business with United Company Rusal plc (Rusal) through October 23, 2018.  The imposition of sanctions on Rusal, which OFAC listed as a Specially Designated National (SDN) on April 6, had roiled the global aluminum market and … Continue Reading

New Sanctions Against Russian Oligarchs, Officials, and Companies May Have Significant Impact

Following up on our earlier blog post, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced new blocking sanctions on April 6, 2018 against seven Russian oligarchs, 12 entities owned or controlled by those oligarchs, 17 senior Russian government officials, a Russian weapons trading company, and a banking subsidiary owned by … Continue Reading

OFAC Sanctions Russian Oligarchs and Major Russian Companies

Today, the U.S. Department of Treasury, Office of Foreign Assets Control (OFAC) designated several Russian individuals and companies as Specially Designated Nationals (SDNs).  Specifically, in response to what Treasury Secretary Steven Mnuchin described as Russia’s “malign activity”, OFAC indicated that it sanctioned seven Russian oligarchs and 12 companies they own or control, 17 senior Russian … Continue Reading

President Imposes First US Economic Sanctions Against Venezuelan Digital Currency

On March 19, President Trump issued Executive Order 13827, which imposes the first US sanctions against a virtual currency – namely, a digital currency known as the “petro” that has been issued by the Government of Venezuela (GOV). Specifically, the executive order prohibits “all transactions related to, provision of financing for, and other dealings in, by … Continue Reading

Newly Introduced Sanctions Bill Targets IRGC

On March 1, House Foreign Affairs Committee Chairman Ed Royce (R-CA) and the committee’s ranking Democrat, Eliot Engel (D-NY), introduced bipartisan legislation targeting Iran’s Islamic Revolutionary Guard Corps (“IRGC”), a branch of Iran’s armed forces considered responsible for much of Iran’s international terrorism and domestic repression.  The new bill, known as the Iranian Revolutionary Guard … Continue Reading

Russia Sanctions: Amended OFAC Directive 4 Effective Today

Today is the effective date of the expanded sanctions set out in Directive 4 under the U.S. Russia sanctions program, as amended by the U.S. Department of Treasury, Office of Foreign Assets Control (OFAC) on October 31, 2017.  The amendment implemented Section 223 of the Countering America’s Adversaries Through Sanctions Act (CAATSA), signed into law … Continue Reading

What if President Trump Refuses to Renew Iran Sanctions Waivers?

Last week, while reluctantly renewing waivers of statutory sanctions against Iran, President Trump issued an ultimatum: Either the United States’ European allies negotiate a “supplemental agreement” that strengthens the Joint Comprehensive Plan of Action (JCPOA) nuclear agreement and targets Iran’s ballistic missile program, or the United States will no longer waive sanctions against Iran.  The President’s … Continue Reading

President Trump Reissues Iran Sanctions Waivers, but Warns That Concerns over JCPOA Must Be Addressed

On January 12, President Trump announced that he was reissuing statutory waivers necessary to continue certain sanctions relief pursuant to the Joint Comprehensive Plan of Action (“JCPOA” or Iran nuclear deal), but stated that this was the last time he would reissue such waivers unless his concerns over the agreement were addressed.  On the same … Continue Reading

Trump Designates North Korea as a ‘State Sponsor of Terrorism,’ Makes Additional Sanctions Designations

On November 20, 2017, President Trump announced that North Korea would be designated a “state sponsor of terrorism.”  The only other countries with this designation are Syria, Iran, and Sudan.  The president also stated that the United States would announce the imposition of additional sanctions on Pyongyang.  The next day, the US Department of the … Continue Reading

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
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