Happy new year everyone. The government is shut down, but there has already been a flurry of activity in 2019 on the economic sanctions and embargoes front. Here is a summary of where we stand on various sanctions regimes.

Russia. On January 10, 2019, the Trump administration defended its decision to ease U.S. sanctions against companies connected to the Russian oligarch Oleg Deripaska. In 2017, the “Countering America’s Adversaries Through Sanctions Act” (CAATSA) passed Congress overwhelmingly and was signed into law by President Trump. As we blogged here and here, CAATSA codified strict Russia sanctions. It also allows Congress to block any termination of sanctions by the Executive. In December 2018, the Treasury department announced that it would lift sanctions on three of Deripaska’s companies: EN+ group, Rusal, and JSC EuroSibEnergo. Though Deripaska would continue to be subject to sanctions personally, Secretary Mnuchin reportedly told members of Congress in a briefing that the three companies had committed to “significantly diminish Deripaska’s ownership and sever his control.” Many lawmakers left the briefing unimpressed, and expressed concern that lifting sanctions would result in a tremendous financial benefit to Deripaska, whose designation by Treasury for sanctions last year reads like a mafia indictment. For now, it is unlikely that Congress is united enough to use its CAATSA powers to maintain the sanctions in the face of the Administration’s decision to lift them. But it is clear that Congressional Democrats intend to exercise their oversight powers when it comes to sanctions (or lack thereof) against Russia.
Continue Reading New Year Sanctions Roundup: Where Do We Stand?

While the Travel Ban continues to move up and down the federal court system, here are the latest rules governing travel for citizens of the affected countries as a result of the U.S. Supreme Court’s lifting of the lower courts’ injunctions on December 4, 2017, a December 22 ruling by the Ninth Circuit invalidating the latest travel ban but not enjoining it, and recent action by a Federal District Court in Seattle partially lifting the refugee ban on December 23, 2017:
Continue Reading Confused by the Evolving Travel Ban? Here’s a Cheat Sheet with the Latest Guidance

By: Mark Jensen and Melinda Lewis

June brought a dark milestone in the Syrian civil war as the death toll exceeded 100,000 since the conflict began nearly two years ago. Amid international and domestic pressure to take action against the Syrian government for the continuing escalation of violence against its people, the United States has issued revised sanctions against Syria and announced its intention to provide arms to the Syrian rebels.
Continue Reading The Internet, Food, Petroleum, and World Culture: Recent Updates to the Syria Sanctions

By: Thad McBride

While the United States has long maintained sanctions on Iran and has expanded those sanctions several times recently, none of those recent actions has had such a direct impact on U.S. companies as the Iran Threat Reduction and Syria Human Rights Act that President Obama signed into on August 10, 2012 (the “Act”).  The Act creates new Iran sanctions, and provides for new sanctions on persons deemed to be involved in committing or supporting human rights abuses in Syria, including, in certain cases, non-Syrian parties.

Continue Reading Iran, Syria Sanctions Strengthened by New U.S. Law

By: Scott Maberry

As illustrated by three recent export enforcement actions, when armed government enforcement agents come to your door with PowerPoint slides, pay close attention. On March 8, 2012, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) and the U.S. Attorney’s Office for the District of Wyoming announced settlements of three related cases involving illegal exports to Syria. The cases involved an increasingly common enforcement tool, the U.S. government “outreach” visit.
Continue Reading Export Control Settlements Highlight the Need to Pay Attention During “Outreach” Visits

By: Curtis Dombek and Dan Brooks

On January 18, 2012, the European Union adopted Council Regulation No. 36/2012 (“Regulation 36/2012”), which imposes new restrictions on companies doing business in Syria.  Regulation 36/2012, which repeals and replaces previous measures adopted by the EU in May 2011, has particular implications for companies operating in the oil and gas, energy, and telecommunications sectors.

Continue Reading EU Imposes New Economic Sanctions on Syria

By: David Gallacher and Thaddeus McBride

In 2011, the world experienced historic events, particularly with regard to the Arab Spring and the violent repression that followed in nations like Libya and Syria.  2011 witnessed the expansion of a number of international sanctions programs, most particularly tied to political developments in countries such as Iran, Syria, Libya, Sudan, Cuba, and North Korea.  Following is a summary of key developments in U.S. sanctions during 2011, as well as a brief look ahead at what may happen in 2012 in countries such as Iran, Yemen, and Myanmar (Burma). 

Continue Reading International Sanctions – Updates to U.S. Sanctions Laws in 2011