The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) recently designated as Specially Designated Nationals (“SDNs”) a number of entities linked to the Iranian steel, aluminum, and iron sectors that are likely to be of particular interest for companies doing trade in or with the Middle East…
Dealing with the compliance challenges presented by near daily new US sanctions and export controls requires a risk-based compliance program that addresses rapid change and mitigates increasing global enforcement risk, while still being practical and business friendly. Executive Summary Most GCs will be familiar, at least to some degree, with…
The US government has taken coordinated actions this week that target Huawei Technologies Co. Ltd (Huawei), effectively cutting it off from sourcing US products and technology and likely barring its products from being used in US communications infrastructure and networks. The US export/reexport restrictions targeting Huawei took effect immediately on…
On May 8, 2018, President Trump announced that the United States will be withdrawing from the Joint Comprehensive Plan of Action (“JCPOA”), culminating months of uncertainty around the fate of the Iran nuclear deal. Furthermore, President Trump announced that the United States would re-impose nuclear sanctions against Iran.
On August 24, 2017, President Trump signed an Executive Order imposing additional sanctions on Venezuela. The Order states that these sanctions, which primarily target the Government of Venezuela and the Venezuelan oil industry, are in response to the deepening political and humanitarian crisis in Venezuela.
On November 12, 2015, President Barack Obama issued Executive Order 13710 ending sanctions related to the Republic of Liberia originally put in place in 2004. On November 23, 2015, President Obama issued an Executive Order imposing sanctions related to the Republic of Burundi primarily due to “the killing of and violence against civilians, unrest, the incitement of imminent violence, and significant political repression” occurring in Burundi
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 9 March 2015, US President Barack Obama issued a new Executive Order(“Order”) authorizing the imposition of sanctions targeting Venezuela in response to the Venezuelan Government’s erosion of human rights guarantees; persecution of political opponents; curtailment of press freedoms; use of violence and human rights violations and abuses in response to…