The U.S. Reacts to Ortega’s Fourth Consecutive Term in Power in Nicaragua

On January 10, 2022, Nicaraguan President Daniel Ortega was sworn into office for his fourth consecutive term, despite the United States and European Union allegations that the election was a “sham.”  On the same day, the U.S. imposed sanctions on Nicaraguan officials accused of undermining democracy. Over the past years, the Office of Foreign Assets … Read more

OFAC expands sectoral sanctions on Belarus

On December 2, 2021, the Office of Foreign Assets Control (OFAC) of the US Department of the Treasury took several actions to increase sanctions pressure on Belarusian government, including the introduction of a new sectoral sanctions regime (Directive 1) targeting certain Belarusian sovereign debt, the designation of 35 additional persons and entities to the Specially … Read more


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


This analysis was first published on Lexis®PSL on 29 October 2021 and can be found here (subscription required). Ivan Teselkin, partner, Maria Dolotova, of counsel, Alexander Gridasov, senior associate, and Sergei Eremin, senior associate, of Herbert Smith Freehills provide an overview of Russian court decisions on the impact of recent amendments to Russian law relating to international … Read more

Bureau of Industry & Security Issues New Export Controls on “Cybersecurity Items”

On October 21, 2021, the Bureau of Industry & Security (BIS) of the US Department of Commerce issued a significant interim final rule (the Interim Rule).  The Interim Rule, reflecting an overall recent government emphasis on cybersecurity and ransomware issues, establishes new export controls for “cybersecurity items” such as intrusion software and network surveillance equipment … Read more

OFAC and FinCEN Publish Virtual Currency Industry and Ransomware Guidance

On October 15, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued an industry-specific brochure entitled, “Sanctions Compliance Guidance for the Virtual Currency Industry” (the “OFAC Guidance”). According to a press release, the OFAC Guidance “outlines sanctions compliance best practices tailored to the unique risks posed in this dynamic space, … 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

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