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

UK, US and Canada impose additional sanctions on Belarus

On 9 August 2021, the UK, US and Canadian governments announced the imposition of additional sanctions on Belarus. These new measures follow the coordinated imposition of sanctions against Belarus by the EU, UK, Canada and the US in June 2021. The new US measures involve, among other restrictions: new US secondary sanctions applicable to companies … Read more

OFAC settlement with online payment-services company highlights key OFAC expectations in sanctions compliance programs

On July 23, 2021, the Office of Foreign Assets Control (OFAC) of the US Department of the Treasury entered a settlement agreement with an online payment-services company business based in New York, Payoneer Inc. (Payoneer). Payoneer, which went public on the Nasdaq exchange in June 2021, provides digital payment services and online money transfer services … Read more

OFAC Reaches Settlement with Alfa Laval Subsidiaries Over Iran Referral

On July 19, 2021, the Treasury Department’s Office of Foreign Assets Control (OFAC) announced that it had entered into settlement agreements with two subsidiaries of Alfa Laval AB, the UAE-based Alfa Laval Middle East Ltd. (“AL Middle East”) and the US-based Alfa Laval Inc. (“AL US”) to settle apparent violations of the Iranian Transactions and … Read more

Biden Administration Adds 34 Entities to BIS Entity List

On July 12, 2021, the Commerce Department’s Bureau of Industry and Security (BIS) published a Federal Register notice amending the Export Administration Regulations (EAR) by adding 34 entities to the BIS Entity List under 43 entries. The Entity List prohibits US companies from exporting or transferring US products and technology to listed entities without a … Read more

Jonathan Cross recently featured in Anti-Corruption Report

Jonathan Cross recently published “Managing Sanctions Risk Up and Down the Supply Chain” in the Anti-Corruption Report. The article looks at the importance of companies ensuring their sanctions compliance procedures address “supply-chain” risks, given the increase in actions brought by The US Treasury Department’s Office of Foreign Assets Control (OFAC); where the subject was one … 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

President Biden Revokes TikTok and WeChat Bans

On June 9, 2021, President Biden issued Executive Order (“EO”) 14034, revoking three Trump Administration Executive Orders which had banned transactions involving Chinese-owned apps on national security grounds (the “Revoked Executive Orders”). Despite revoking the bans, EO 14034 acknowledged concerns about software applications controlled by a “foreign adversary” and directed federal agencies to investigate and … Read more