On 2 May 2019, the US Office of Foreign Assets Control (OFAC) published A Framework for OFAC Compliance Commitments (Framework). This long-awaited document sets out OFAC’s expectations for effective sanctions compliance programs (SCPs). While the broad elements of the Framework should be familiar to seasoned compliance practitioners, the details highlight…
On December 19, 2018, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) submitted a letter to congressional leaders (“Congressional Letter”) notifying Congress of its intent to terminate the sanctions imposed on En+ Group plc (“En+”), UC Rusal plc (“RUSAL”), and JSC EuroSibEnergo (“ESE”) in 30 days. …
October 2018 The state of United States (US), European Union (EU), and other sanctions regimes is in flux like never before, with significant implications for Middle East trade and finance. US sanctions against Iran are increasing following the US withdrawal from the Iran nuclear deal (the 2016 Joint Comprehensive Plan of Action (JCPOA)),…
Baker McKenzie is pleased to invite you to interactive seminars in Abu Dhabi and Dubai in October 2018 to discuss the implications of recent US and EU sanctions on international trade.
The Order implements the Global Magnitsky Human Rights Accountability Act and targets human rights abusers and corrupt actors globally.
Last month, the US Senate passed significant Russia sanctions legislation. Last Friday, the Senate and House of Representatives reached agreement to advance the bill. The House approved the bill yesterday.
On January 26, 2016, the U.S. OFAC and the U.S. BIS announced amendments to the Cuban Assets Control Regulations and the Export Administration Regulations to engage and empower the Cuban people.
On May 22, 2015, the US Government relaxed certain export and reexport controls imposed under US sanctions targeting the Crimea region of Ukraine (“Crimea”). Specifically, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued a new General License authorizing the export or reexport from the United States or…
On March 25, 2015, a reissued version of the U.S. Department of Energy (“DOE”) regulations on “Assistance to Foreign Atomic Energy Activities,” 10 C.F.R. Part 810 (“Part 810” or “the DOE Regulations”), go into effect. The DOE Regulations control the provision outside the United States of technology and other assistance…
When the U.S. Congress enacted the Foreign Corrupt Practices Act (“FCPA”) in 1977, the public record revealed a debate over what should constitute “knowledge” of an improper payment under the anti-bribery provisions of the statute. There was no controversy over “actual knowledge” since it was clear that a company or…