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On January 10, 2017, Senate Republicans and Democrats introduced bi-partisan legislation called the “Countering Russian Hostilities Act of 2017,” which would impose broad sanctions on Russia. The Act would codify the sanctions President Obama imposed in response to the Russian cyberattack on the United States to influence the 2016 U.S. Presidential election and the Ukraine-related sanctions President Obama issued in 2014. Importantly, the legislation introduces beefed up economic sanctions against Russia’s energy and financial sectors.
Continue Reading The Future of Russia Sanctions: The Awkward Edition

On July 16, the U.S. Department of Treasury, Office of Foreign Assets Control (OFAC) imposed new sanctions against Russia, which target the country’s financial, energy and defense sectors.  In a parallel action, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) added 11 parties to its Entity List based on their role in the destabilization of eastern Ukraine and the ongoing occupation of Crimea and Sevastopol.
Continue Reading CLIENT ALERT: United States Imposes New Sanctions and Export Restrictions Against Russian Banks, Companies, and Individuals

The pressure on Russia continues to build.  As we previously reported here and here, throughout March, the United States and other Western powers implemented a series of sanctions against individuals and entities deemed to be involved in the political destabilization of Ukraine.  Those sanctions were restricted to specific parties, including high ranking Russian and Ukrainian officials and – notably – one Russian bank.
Continue Reading Starving the Bear: The United States Restricts Exports to Russia

In response to Russia’s military presence in the Crimean region of Ukraine, President Obama issued an Executive Order (“EO”) on March 6, 2014, authorizing the blocking of property of individuals and entities involved in the political destabilization of Ukraine. The EO provides categories of persons subject to the sanctions but leaves the U.S. Treasury and State Departments to designate the specific persons covered by the EO.
Continue Reading The Gloves are Off: U.S. Sanctions Block Aggressors in Crimea

On March 5, 2014, the U.S. Department of Justice announced that it had frozen over $458 million of ill-gotten assets that former Nigerian dictator Sani Abacha and his co-conspirators had stashed in bank accounts across the globe.  The DOJ is seeking to recover almost $100 million more.  The largest-ever kleptocracy forfeiture action brought in the United States, this case is a victory for the Kleptocracy Asset Recovery Initiative, a program launched by the DOJ Criminal Division’s Asset Forfeiture and Money Laundering Section in 2010.  We wrote about the Initiative’s first-ever action here, brought in 2012, when the DOJ executed a forfeiture order of just over $400,000 against a former Nigerian governor.  And while the DOJ has seen great success in its actions against bribe-payers through the enforcement of the Foreign Corrupt Practices Act, initiatives to bring bribe-takers to justice have faced bumps in the road, probably because of the politically fraught and complex nature of such cases.
Continue Reading It Doesn’t Pay to Steal: In Largest Ever Kleptocracy Forfeiture Action, DOJ Seizes $458 Million