On June 12, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced new measures targeting Russia’s financial infrastructure, including:Continue Reading OFAC Tightens Russia Sanctions; BIS Cracks Down on Diversion
E(U)xterritoriality of EU Sanctions: The No Russia Clause
The EU is going extraterritorial, and it is doing so through private contract. It is a pretty neat trick.Continue Reading E(U)xterritoriality of EU Sanctions: The No Russia Clause
The EU’s 11th Sanctions Package: The Long(er) Arm of the Law
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
Friday Development: New Sanctions and Export Controls to Address Russia’s Ongoing Aggression in Ukraine (Including the use of Iranian UAVs)
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)
U.S. and Allies Impose Additional Russia Sanctions After Sham Annexations
In response to Russia’s illegal declaration of annexations of Ukrainian territory, the United States and the European Union have imposed additional sanctions on Russia.Continue Reading U.S. and Allies Impose Additional Russia Sanctions After Sham Annexations
Flying the Too-Friendly Skies? Europe Opens Routes for Sanctioned Iran Airline
On June 20, 2016, you will be able to take a non-stop flight from Tehran to Paris . . . but you probably shouldn’t.
According to its website, the Iranian airline Mahan Air will add the City of Lights to the list of European destinations it is already serving, including Athens, Copenhagen, and Dusseldorf. What makes the current and proposed Mahan routes interesting to regulatory experts (read: nerds) is that Mahan Air is on the U.S. Treasury’s Specially Designated Nationals (SDN) list. According to the Treasury’s Office of Foreign Assets Control (OFAC), Mahan Air has moved troops and equipment for the Iranian Revolutionary Guard Corps and has provided support and transport to the Assad regime in Syria.Continue Reading Flying the Too-Friendly Skies? Europe Opens Routes for Sanctioned Iran Airline
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 Keep Your Frenemies Close: Proposed China Sanctions and the Price of Escalation
Accounts and Accountability: Arab Bank Found Liable for Transactions Under the Anti-Terrorism Act
On September 22, 2014, a Brooklyn jury found Arab Bank, Jordan’s largest lender, guilty of violating the U.S. Anti-Terrorism Act for providing financial services to individuals and entities linked to Hamas. Hamas is currently designated as a terrorist organization by the U.S. Treasury Department, Office of Foreign Assets Control (OFAC), and is listed on the Specially Designated Nationals List that OFAC maintains. Plaintiffs, victims and family members of victims of terrorist attacks, alleged that Arab Bank customers included members of Hamas and also a charitable organization, Saudi Committee, that sent payments to family members of Hamas suicide bombers. But not all of the individuals were on the SDN list, and neither was Saudi Committee.
Continue Reading Accounts and Accountability: Arab Bank Found Liable for Transactions Under the Anti-Terrorism Act