EXPANSION TO AUSTRALIA’S SANCTIONS REGIME PASSED BY PARLIAMENT

On 2 December 2021 the Australian Parliament passed the Autonomous Sanctions Amendment (Magnitsky-style and Other Thematic Sanctions) Bill 2021 (Bill) introducing a new thematic sanctions regime to the Autonomous Sanctions Act 2011 (Act) and Autonomous Sanctions Regulations 2011 (Regulations). As outlined in our previous update, the amendments expand Australia’s existing autonomous sanctions regime (which enabled Australia to … Read more

Designated: A Sanctions Podcast EP3: Cross over event with The Bettor’s Verdict

In a special podcast cross over event, the Designated team joins The Bettor’s Verdict to discuss the Impact of Crypto on Sanctions and AML Laws in the United States.  In this episode, Designated host Jonathan Cross, is joined by The Bettor’s Verdict host Steve Jacobs, and Herbert Smith Freehills Partner John O’Donnell. Jonathan, Steven and … Read more

OFAC Enters Settlement Agreement With a U.S. Company Related to Certain Exports to Iran Through Non-U.S. Distributors

On September 9, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) entered a settlement agreement with NewTek, Inc. (“NewTek”), headquartered in San Antonio, Texas. According to a press release, NewTek agreed to pay $189,483 to settle its potential civil liability for 52 apparent violations of the Iranian Transactions and Sanctions … Read more

European Commission launches new public consultation seeking feedback to possible amendments to the EU Blocking Statute

In August 2021, we published a post about the European Commission’s roadmap / inception impact assessment in relation to its review of the current Blocking Statute (Regulation 2271/96). On 31 August 2021, the European Commission closed the initial feedback period for this impact assessment and, as a next step, has now launched a public consultation process seeking further feedback … Read more

Designated: A Sanctions Podcast EP2: History of US Sanctions Under the JCPOA May Offer Insight to Terms of Renewed JCPOA Participation

In this episode, Jonathan Cross, Brittany Crosby-Banyai and Dan Hudson discuss the history of the Iran sanctions program under the Iranian nuclear deal, known as the Joint Comprehensive Plan of Action (“JCPOA”). They also analyze the mechanisms by which sanctions were re-imposed when the US left the agreement. These considerations offer insight as to the … Read more

Proposed reforms to Australia’s sanctions regime to target corruption, cyber-crime, human rights violations

The Australian Government has announced plans to implement a targeted, Magnitsky-style sanctions regime by the end of 2021. What are the implications of the proposed reforms? The proposed reforms would expand Australia’s current country-based autonomous sanctions framework to include targeted sanctions focused on themes of conduct. This includes proliferation of malicious cyber activity, gross human … Read more

OFAC Issues Sanctions in Response to Belarus’s Forced Diversion of a Ryanair Flight

On June 21, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated sixteen individuals and five entities pursuant to Executive Order (“E.O.”) 13405 of June 16, 2006, entitled “Blocking Property of Certain Persons Undermining Democratic Processes or Institutions in Belarus.” According to a press release, OFAC designated these individuals and … Read more

New Commission opinion on EU sanctions and “making available”: the impact of a non-sanctioned company and its subsidiaries of having a Designated Person director

On 8 June 2021, the European Commission published an opinion on Article 2(2) of Council Regulation (EU) No 269/2014 of 17 March 2014 (the “Regulation”). The Regulation imposes an asset freeze on certain Russian individuals and entities in response to the situation in Ukraine. Article 2(2) contains the standard EU asset freeze wording providing that “no funds or economic … Read more