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On November 10, 2023, the Office of Foreign Assets Control (“OFAC”) sent notices to ship management companies in nearly 30 countries inquiring about the operations of 100 vessels suspected of facilitating operations in violations of U.S. sanctions related to Russian oil. While OFAC refused to “confirm or comment on investigations or enforcement actions” an OFAC … Read more
On February 6, 2023, powerful earthquakes devastated Turkey and Syria. Media reports indicate that the first earthquake, “which hit near the town of Gaziantep, was closely followed by numerous aftershocks – including one quake which was almost as large as the first.” The destruction caused by these earthquakes has toppled thousands of buildings, killed and … Read more
On October 7, 2022, the Department of Commerce’s Bureau of Industry and Security (“BIS”) took two significant actions with major implications for companies and persons dealing with the Chinese semiconductor and electronics sectors: BIS issued an interim final rule (the “IFR”) targeting exports to the People’s Republic of China that, among other things, imposes sweeping … Read more
Illustrating the trend of coordinated sanctions actions taken by the Treasury and Commerce Departments, last week the Office of Foreign Assets Control (“OFAC”) worked in tandem with the Commerce Department Bureau of Industry and Security to publish an Alert entitled, “OFAC-BIS Alert: Impact of Sanctions and Export Controls on Russia’s Military-Industrial Complex,” which discusses the … Read more
In this mini-series, we discuss the recent sanctions measures implemented in the U.S., E.U., and U.K. as a response to the crisis in Ukraine. In this episode, Jonathan Cross, Susannah Cogman, and Brittany Crosby-Banyai focus on the recent sanctions measures that impact Russian investments. Read more
On July 27, 2022, the US Senate unanimously passed a nonbinding, bipartisan resolution to designate the Russian Federation as a “State Sponsor of Terrorism” (SST). In parallel, a bipartisan group of members of the US House of Representatives introduced a bill on July 28, 2022 to designate Russia as an SST. See H.R.8568. These actions … Read more
On June 21, 2022, U.S. Customs and Border Protection (“CBP”) began enforcing the Uyghur Forced Labor Prevention Act (Pub. L. 117-78) (the “UFLPA”), which establishes a “rebuttable presumption” that goods produced wholly or in part in the Xinjiang Uyghur Autonomous Region (“XUAR”) in China or by certain identified entities are made with forced labor, and … Read more
Updates from March 19, 2022 through April 12, 2022 Within a brief period, the international sanctions environment applicable to trade with Russia has been fundamentally transformed. We have published a number of recent updates regarding sanctions measures that have been proposed and enacted in several jurisdictions as a response to the crisis in Ukraine. These … Read more
In the United States government’s latest response to the crisis in Ukraine, it imposed broad new investment and services restrictions pursuant to a new executive order, new sectoral restrictions, and the designation of a substantial number of additional individuals and entities on OFAC’s Specially Designated Nationals and Blocked Persons (“SDN”) List, including two major Russian … Read more
