On April 6, 2018, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced new designations of seven high-net-worth Russian individuals and 12 companies they own or control, 17 senior Russian government officials, and a state-owned Russian weapons trading company and its subsidiary, a Russian bank. Continue reading


Following our earlier bulletin, on October 31, 2017, the US Department of State and Department of Treasury’s Office of Foreign Assets Control (“OFAC”) posted comprehensive guidance related to the Countering America’s Adversaries Through Sanctions Act of 2017 (“CAATSA”). The new guidance addresses multiple provisions of CAATSA, mainly the provisions concerning secondary sanctions targeting Russia. The new guidance significantly limits and clarifies the scope of these secondary sanctions.

As detailed in our prior alert, on August 2, 2017, President Trump signed CAATSA into law. The legislation provided several new categories of primary and secondary sanctions relating to Russia, Iran and North Korea.

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H.R. 3364 (the “Countering America’s Adversaries Through Sanctions Act”) overwhelmingly passed the House and Senate and has now been signed into law by the US President, albeit with two partly critical signing statements (here and here). The law represents significant development in sanctions against Iran, North Korea, and Russia.

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US Senate approves Russia sanctions amendment

A bipartisan US Senate coalition has approved a wide-ranging package of new Russia-related sanctions as an amendment to the Countering Iran's Destabilizing Activities Act of 2017 ("S.722" or "Iran Sanctions Bill") currently pending before Congress. The changes contemplated by these provisions-dubbed-Countering Russian Influence in Europe and Eurasia Act of 2017 ("CRIEEA" or the "Amendment") would codify existing Russia-related sanctions and mandate congressional review of any attempts by the President to modify or terminate them.

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EU extends the duration of asset freeze in relation to Ukraine’s territorial integrity

On 15 September 2016, the European Council announced that the EU's Russia-related asset freezing measures imposed in relation to Ukraine's territorial integrity, sovereignty and independence (which were previously due to expire on 15 September 2016) will be extended for a further six months until 15 March 2017.  This extension was effected by Council Decision (CFSP) 2016/1671 of 15 September 2016 (the "Decision"), amending Council Decision 2014/145/CFSP. The Decision came into force upon publication in the Official Journal on 16 September 2016.

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EU extends duration of sanctions against Russia and Crimea & Sevastopol

The EU has recently announced an extension of its sanctions imposed in response to the situation in Ukraine. EU leaders had previously confirmed that the duration of sanctions affecting Russia would be linked to the implementation of the Minsk Agreements, currently foreseen to be completed by 31 December 2015. The EU has therefore taken steps to extend the validity of its sanctions against Russia beyond this period; the underlying Council Decisions would otherwise have expired before the Minsk Agreements are expected to be fully implemented.

This briefing provides a summary of the new EU legislation and the revised expiry dates of the various measures. There have been no substantive changes to the restrictive measures and EU persons should therefore continue to comply with all applicable measures.

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A changing landscape: regulatory developments in the distribution of retail investment products – UK, France, Spain, Germany, Italy, Netherlands, Switzerland, Russia, UAE and Hong Kong

Over the last 18 months, we have seen significant momentum in regulatory developments regarding the distribution of retail investment products, driven by calls at both national and European level to protect consumers better. This movement has been fuelled by the desire to remedy perceived regime failings, many of which were exposed by the financial crisis. These wide-ranging reforms indicate that a change in the regulatory landscape is underway.

We have published the second edition of our guide which assists those with global businesses involved in the distribution of retail investment products, in navigating their way through the differing regimes in the UK, France, Germany, Spain, Italy, Netherlands, Switzerland, Russia, the United Arab Emirates and Hong Kong. Continue reading