Sanctions Lawyer

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On June 23, 2023, the EU released its 11th package of sanctions on Russia. This package is designed to improve enforcement with new anti-circumvention rules, new trade restrictions, and new designations. The anti-circumvention rules are quite a novel aspect and could result in the first extraterritorial reach of European sanctions.Continue Reading The EU’s 11th Sanctions Package: The Long(er) Arm of the Law

In response to Russia’s ongoing aggression in Ukraine, both the United States and the European Union have imposed additional sanctions and further restricted exports to Russia and Iran. These new controls span many industries.Continue Reading Friday Development: New Sanctions and Export Controls to Address Russia’s Ongoing Aggression in Ukraine (Including the use of Iranian UAVs)

Today, the Financial Action Task Force (FATF) officially moved Myanmar onto the agency’s blacklist, where it joins Iran and North Korea, the only other two listed countries. It is likely that the United States and other countries will take the FATF designation as grounds to impose financial sanctions on the country, likely focusing on its central bank and financial institutions.Continue Reading Myanmar Sanctions – A Last Resort Against a Non-Cooperating Country

After Mahsa Amini was killed in the custody of “Gasht-e-Ershad” or Iran’s Guidance Patrol, commonly referred to as Iran’s morality police, following an arrest for placement of her hijab, protests have erupted throughout Iran over women’s rights and Iran’s authoritarian regime more generally. Iran’s police and other security forces are retaliating severely against protestors. In response to these human rights abuses, on September 22, the U.S. Department of Treasury, Office of Foreign Assets Control (OFAC) sanctioned Iran’s morality police and senior leaders of Iran’s security organizations for the violence against protesters.Continue Reading Technology to Iran: OFAC Lifts Certain Iran Sanctions In Response to Protests in Iran

On July 7, 2022, the Treasury Department laid out how it would work with its overseas counterparts and in international forums as the U.S. studies cryptocurrencies to set up a possible regulatory regime. This framework is the first executive agency response as mandated President Biden’s March executive order on crypto that we wrote about here.Continue Reading Treasury Department Seeks to Coordinate Globally on Crypto Regulation

On May 6, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated a cryptocurrency mixer, Blender.io, as a Specially Designated National (SDN). That sanction follows a series of enforcements and sanctions which we have previously discussed here and here.Continue Reading The Crypto Enthusiast and The Regulator: What OFAC is, Could Be, and Should Be Doing to Regulate CryptoCurrencies

  • New law could penalize companies for complying with U.S. sanctions.
  • Penalties include designation to China’s new “Unreliable Entity” list.
  • Statements against the new laws could also be penalized, restricting the capacity of counsel to advise freely on compliance with U.S. sanctions and Chinese countermeasures.

On June 10, 2021, China enacted the Anti-Foreign Sanctions Law (“AFSL”), aimed at punishing countries that impose anti-China sanctions and the companies that comply with those sanctions. The law is effective immediately, and applies to any sanctions imposed against China, Chinese entities, or Chinese individuals by any third country (excluding sanctions adopted by the United Nations).

The AFSL comes in addition to the Measures on Blocking Unjustified Extraterritorial Application of Foreign Legislation (the Blocking measures) issued earlier this year. Those measures were mainly address the extraterritorial effect of U.S. sanctions against China, by punishing companies that comply with U.S. sanctions.
Continue Reading Counterpunch: China Adopts Landmark Anti-Sanctions Statute to Stop U.S. Sanctions Effects Overseas