Biden Lifts ICC Sanctions, US Moves Closer to Iran Deal

The Biden Administration has announced several significant decisions over the past few days. On April 1, President Biden signed Executive Order 14022 (the “EO 14022”), terminating the national emergency declared in Executive Order 13928, dated on June 11, 2020 (“EO 13928”). EO 14022 reverses EO 13928, which blocked the property of certain persons associated with … Read more

US Expands Myanmar Sanctions Measures

We continue to closely monitor the international response to the political situation in Myanmar and are providing regular updates in relation to sanctions and other developments that may impact international businesses with interests or operations in Myanmar. For further information on the current situation, please get in touch with one of our key contacts below. … Read more

Myanmar sanctions tracker

We continue to closely monitor the international response to the political situation in Myanmar and are providing regular updates in relation to sanctions and other developments that may impact international businesses with interests or operations in Myanmar. For further information on the current situation, please get in touch with one of our key contacts below. … Read more

BitPay Settlement Signals Growing OFAC Focus on Cryptocurrency Transactions

On February 18, 2021, BitPay, Inc. (“BitPay”), a major cryptocurrency payment processing platform, entered into a $507,000 settlement with the Office of Foreign Asset Control (“OFAC”), to settle allegations that it processed cryptocurrency payments which violated various US sanctions programs.  Significantly, OFAC did not allege that BitPay knowingly violated sanctions laws or took steps to … Read more

OFSI updates its guidance on the imposition of monetary penalties

The Office of Financial Sanctions Implementation (“OFSI”) published an updated version of its “Monetary penalties for breaches of financial sanctions – guidance” (the “Guidance”) on 10 March 2021. The updated Guidance comes into force on 1 April 2021. Any breaches reported to OFSI after this date will be dealt with under the new guidance. OFSI … Read more

Biden Administration Rescinds Re-Imposition of UN Sanctions, Calls for Renewed JCPOA Negotiations with Iran

On February 18, 2021, the Biden Administration rescinded the United States’ re-imposition of United Nations sanctions against Iran, which were lifted as part of the Iran nuclear deal known as the Joint Comprehensive Plan of Action (“JCPOA”). The rescission is another step in the Biden Administration’s continuing efforts to have the United States re-join the … Read more

OFAC De-designates Ansarallah, Completing Reversal of Trump Administration Yemen Policy

On February 16, 2021, the US Department of Treasury’s Office of Foreign Assets Control (“OFAC”) revoked the designations of Ansarallah, the Yemeni political and para-military organization also known as the Houthis, under the Global Terrorism Sanctions Regulations (“GTSR”), the Foreign Terrorist Organization Sanctions Regulations (“FTOSR”), and Executive Order 13244. As a result, US persons no … Read more

Upcoming Webinar: Sanctions Under the New Administration

The Herbert Smith Freehills global sanctions team invites you to join them for a webinar, to discuss: potential US sanctions implications of the impending change of Administration with respect to Venezuela, China and Russia-related sanctions, as well as the prospects for increased general emphasis on human rights and anti-corruption issues in US sanctions and trade … Read more

New year, new UK sanctions regime

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