“Every export—every single one—has a related financial transaction”Continue Reading Banks Do Export, Too: New BIS Guidance Tags Financial Firms with Export Compliance Responsibilities

Timely Updates and Analysis on Key International Trade Law Issues
“Every export—every single one—has a related financial transaction”Continue Reading Banks Do Export, Too: New BIS Guidance Tags Financial Firms with Export Compliance Responsibilities
On December 22, 2023, President Biden signed a new Executive Order (E.O. 14114) containing the latest round of sanctions against the Russian Federation. Shortly thereafter…
Continue Reading New Russia Sanctions Intensify Pressure on Banks WorldwideWith Russian forces massing at the Ukrainian border, the U.S. and EU have been warning of severe economic sanctions. While we wait and watch this brinksmanship play out, it is worth considering how businesses, and particularly banks, might prepare for what comes next.
Continue Reading A Ruble Without a Cause: What Economic Sanctions on Russia May Mean for Your Business and Global Finance
Article Highlights:
After the Iran nuclear agreement, as non-U.S. companies entered into newly-permitted business in Iran, they faced the difficult question of where they could put the money from their Iran business. U.S. law still prohibits U.S. persons (including U.S. banks) from conducting most business with Iran. Among other rules, OFAC regulations and guidance provided that “Iran-related” funds could not transit the U.S. financial system. But the guidance did not state clearly what constituted “Iran-related” funds. For that reason, foreign financial institutions (FFIs) hesitated, even feared, to process Iran-related transactions because of the risks of sending Iran-related funds into the U.S. financial system in violation of U.S. sanctions. However, a new clarification in the OFAC guidance could change all of that (and change it in the way we proposed right here in this blog[1]).Continue Reading Those Three Little Words: OFAC’s Subtle Language Shift Could Create Sweeping Change on Iran Investment
After a twelve-year standoff that saw the United States and Europe ratchet up sanctions pressure on Iran, a diplomatic breakthrough has been reached. But robust trade between Iran and the West will not arise immediately, since the end of sanctions is a long way away.
Continue Reading Implementation Day: Do the Rules Let You Play in the New Ballgame for Business in Iran?
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 read our reporting on the BNP Paribas penalty of $8.9 Billion (again, that is a “B”) for similar sanctions violations.
Continue Reading The Broader Problem: European Bank Creates an Easy Catch for the Long Arm of U.S. Jurisdiction
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