SAP SE Settlement With US Federal Agencies Signals Additional Sanctions and Export Controls Compliance Burden

    On April 29, 2021, SAP SE (SAP), a leading international provider of enterprise application software based in Germany, entered into settlements and a non-prosecution agreement (collectively, the SAP settlements) with US federal agencies for alleged violations of US sanctions and US export controls with respect to Iran.   SAP entered into a non-prosecution agreement with the … Read more

    UK Introduces Global Anti-Corruption Sanctions

    On 26 April 2021, the United Kingdom introduced new unilateral sanctions against 22 individuals accused of involvement in significant corruption cases in Russia, South Africa, South Sudan and throughout Latin America. The Global Anti-Corruption Sanctions Regulations 2021 (the “Anti-Corruption Regulations”), made pursuant to the Sanctions and Anti-Money Laundering Act 2018 (“SAMLA”) (our full briefing on SAMLA is available here), are … Read more

    OFAC Clarifies That NGOs and Foreign Financial Institutions Do Not Risk Exposure to US Secondary Sanctions by Providing Humanitarian Assistance to Syria

    On April 5, 2021, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published two new Frequently Asked Questions (“FAQs”) related to Syria. Generally, OFAC issues public guidance related to its sanctions programs in the form of FAQs published on its website. FAQ 884 clarifies that, with respect to non-US persons, OFAC … Read more

    OFAC Sanctions Key State-Owned Timber and Pearl Enterprises in Myanmar

    On April 21, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated two state-owned enterprises, Myanma Timber Enterprise (“MTE”) and Myanmar Pearl Enterprise (“MPE”). MTE and MPE were designated pursuant to Executive Order 14014, “Blocking Property With Respect to the Situation in Burma [also known as ‘Myanmar’],” for being a … Read more

    Biden Administration Announces New Russia-Related Sanctions in Response to Cybersecurity, Election Interference, Energy Issues

    On April 15, 2021, President Biden issued a new Executive Order Blocking Property With Respect To Specified Harmful Foreign Activities Of The Government Of The Russian Federation (the “EO”). The EO does not impose general restrictions on trade involving the US and Russia, but instead adopts a more targeted approach. Specifically, the EO imposes new … Read more

    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