Category Archives: Sanctions

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Layover in Tehran: United States Authorizes Carriers to Land Civil Aircraft in Iran

On July 29, 2016, the U.S. Treasury Office of Foreign Assets Control (OFAC) cleared the runway for non-U.S. operators of civil aircraft to send flights into Iran. New  “General License J” authorizes many Boeing, Airbus, and other civil aircraft containing U.S.-origin materials to fly to Iran on “temporary sojourn.” The General License provides a great … Continue Reading

Buying Russian Bonds: Risky Business or Safe Bet?

In late May, The Russian Federation issued its first sovereign bond since the Ukraine crisis in 2014. The sole organizer of the bond is VTB Capital, an arm of VTB Bank, Russia’s second largest financial institution. Both VTB Capital and VTB Bank are subject to sectoral sanctions. According to published reports, the 10-year bond is … Continue Reading

New Business Opportunities in Iran! But Who Will Be Your Banker? Non-U.S. Banks Hesitant to Process Lawful Iran Transactions…and for Good Reason

Highlights: Sanctions relief presents new business opportunities with Iran Most U.S. companies are still prohibited from Iran business, but the U.S. government is encouraging lawful business by non-U.S. companies The line between permitted and prohibited financial transactions by non-U.S. banks is not clear Careful advice of counsel is critical… Continue Reading

The Day of North Korea Sanctions: the UN Imposes the Toughest North Korea Sanctions Yet While OFAC and State Designate More North Korean Entities

After weeks of negotiations and a Putin-backed delay, the UN Security Council unanimously adopted resolution 2270 on March 2, 2016, imposing new sanctions against North Korea. According to U.S. Secretary of State John Kerry, the resolution imposes the strongest set of UN sanctions in over two decades. This article provides a summary of the new … Continue Reading

Airplanes, Pistachios, and a New Burger Joint in Tehran: What Changes for the United States Under Lighter Iran Sanctions

On January 16, 2016, two NFL playoff games and a historic revision of U.S. foreign policy took place. Many of us enjoyed the first two (did you see that last-second touchdown pass?!) but did not pay close attention as the United States lifted many of its secondary sanctions against Iran. Even those normally attentive to … Continue Reading

When Voluntary Self-Disclosure Isn’t so Voluntary: SEC Says Self-Disclose or Forfeit Non-Prosecution and Deferred Prosecution

You may have heard of the Yates Memorandum, which sets forth current Justice Department policy on corporate cooperation with criminal investigations. But the Securities and Exchange Commission has just announced another significant policy change, which hasn’t garnered the same attention: self-disclose or forfeit access to key favorable case dispositions.… Continue Reading

Keep Your Frenemies Close: Proposed China Sanctions and the Price of Escalation

On August 30, 2015, the Washington Post broke a story that the Obama administration is developing a package of economic sanctions that will target Chinese companies and individuals who have benefitted from cybertheft. The new sanctions would come at a time when commerce between the two countries is thriving, but political relations are strained.… Continue Reading

A Break From the Past: Historic Deal with Iran Marks A New Day in U.S.-Iran Relations

Today, President Obama announced a landmark agreement with Iran designed to prevent Iran from obtaining a nuclear weapon in exchange for lifting sanctions that have retarded the country’s development for the decades since the revolution. The agreement is the result of 20 tough months of negotiations among Iran and the so-called P5+1 (the United States, … Continue Reading

UPDATE: Iran Nuclear Deal

Iran and the Western powers have agreed to agree again. On April 2, 2015, the so-called P5+1 (the United States, the UK, China, France, and Russia) along with the EU, have joined Iran in announcing that they have reached a set of broad “parameters” to be negotiated in detail between now and June 30, 2015, regarding … Continue Reading

The Broader Problem: European Bank Creates an Easy Catch for the Long Arm of U.S. Jurisdiction

On March 12, 2015, Commerzbank AG, Germany’s second largest bank and a global financial institution, agreed to pay $1.45 Billion (yes, with a “B”) in forfeitures and fines to the U.S. Government for violating U.S. sanctions against Iran and Sudan. The amount paid by Commerzbank under the settlement will not be shocking to those who … Continue Reading

Paying the Piper: PayPal Inc. Settles Sanctions Violations with OFAC for $7.7 Million

On March 25, 2015, the Department of Treasury’s Office of Foreign Assets Control (OFAC) announced that PayPal Inc. (“PayPal”) agreed to pay $7.7 million to settle 486 violations of U.S. economic sanctions.  According to OFAC, for several years until 2013, PayPal, one of the world’s largest electronic payment companies, did not have adequate compliance processes … Continue Reading

The First Law of International Dynamics: Sanctions May Be Transformed But Never Created or Destroyed

U.S. economic sanctions, by their nature, often change without warning. Since sanctions reflect U.S. foreign and national security policy, they must evolve rapidly with world events. Often, it seems that when one door is closed, another is opened. Most recently, President Obama’s December 17 announcement of an opening to Cuba was followed rapidly by the … Continue Reading

Turnin’ Havana to Atlanta: The White House Opens Doors for U.S. Telecommunications Investment in Cuba and Latin America

Historic changes in relations between the United States and Cuba (that touch nerves in Hip-Hop and on Capitol Hill) and new U.S. sanctions against Venezuela may provide increased opportunities for U.S. business generally, and electronic communications technologies and infrastructure providers in particular.  This week’s Cuba and Venezuela headlines, combined with recent and historic shifts in … Continue Reading

New Russian Sanctions Legislation

On December 18, the President signed legislation passed by Congress that authorizes further sanctions on Russia.  The Ukraine Freedom Support Act of 2014 (UFSA) is aimed to assist “in restoring Ukraine’s sovereignty and territorial integrity” and to deter the Russian Government “from further destabilizing and invading Ukraine and other independent countries in Central and Eastern … Continue Reading
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