Upon the end of the Brexit transition period at 11pm on 31 December 2020, the UK ceased to implement EU sanctions. UK sanctions are now in force under the UK’s domestic sanctions regime, the framework for which is contained in the Sanctions and Money Laundering Act 2018 (“SAMLA”). The UK has introduced regulations under SAMLA … Read more

On December 14, the US Department of State removed Sudan from the US State Sponsors of Terrorism List (“SST List”). The State Department explained that, “[t]his achievement was made possible by the efforts of Sudan’s civilian-led transitional government to chart a bold new course away from the legacy of the Bashir regime and, in particular, … Read more

On December 14, OFAC published a new “Non-SDN Menu Based Sanctions List.” The publication is designed to be a reference tool that identifies individuals and entities subject to certain non-blocking menu-based sanctions. OFAC’s publication is available here. “Menu-based” sanctions authorize the relevant agency to select one or more sanctions from a menu of options. OFAC … Read more

On November 19, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Financial Crimes Enforcement Network, the National Credit Union Administration, and the Office of the Comptroller of the Currency issued a joint fact sheet to provide clarity to banks regarding how to apply a risk-based approach to charities … Read more

On 7 December 2020, the Council of the EU announced the introduction of a new global human rights sanctions regime, as part the EU Action Plan on Human Rights and Democracy 2020-2024. The new regime introduces a framework to impose a travel ban and asset freeze on individuals and entities identified as responsible for, involved … Read more

In series of coordinated actions and announcements during the course of October and November 2020 (the Recent Iran Actions), three US federal agencies—the US Department of State (DOS), the Office of Foreign Assets Control (OFAC) of the US Department of the Treasury, and the US Department of Justice (DOJ)—targeted both Iranian and non-Iranian entities and … Read more

On November 17, OFAC issued General License 8G, Authorizing Transactions Involving Petróleos de Venezuela, S.A. (“PdVSA”) Necessary for the Limited Maintenance of Essential Operations in Venezuela or the Wind Down of Operations in Venezuela for Certain Entities (“GL 8G.”). GL 8G, like its predecessor General License No. 8F (“GL 8F”), authorizes several  US energy companies … Read more

On October 30, OFAC published an advisory (the “Advisory”), which highlights sanctions risks arising from transactions involving high-value artwork associated with persons on OFAC’s List of Specially Designated Nationals and Blocked Persons (“SDNs”). OFAC suggests that “high-value artwork” generally includes artwork with an estimated market value of more than $100,000 USD. OFAC explains that certain … Read more