Sanctions Tracker Summary – Global Sanctions Responses to the Crisis in Ukraine

Updates from February 4, 2022 through March 11, 2022. Within a brief period, the international sanctions environment applicable to trade with Russia has been fundamentally transformed, such that Russia is, in many respects, now a comprehensively sanctioned jurisdiction.  We have published a number of recent updates regarding sanctions measures that have been proposed and enacted … Read more

Sanctions Tracker – Japan Update on Sanctions Responses to the situation in Ukraine

In response to Russia’s ongoing actions with respect to Ukraine, including the “annexation” of Crimea in 2014, Japan had already implemented the following financial sanctions, in place since 2014: to freeze assets of individuals and entities considered to be directly involved in the annexation of Crimea or the destabilisation of the eastern part of Ukraine; … Read more

U.S. Regulators Publish Myanmar Sanctions Advisory

On January 26, 2022, the U.S. government issued an advisory discussing certain risks and considerations for businesses and individuals with exposure to entities responsible for “undermining democratic processes, facilitating corruption, and committing human rights abuses” in Myanmar (the “Advisory”). According to a press release, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) … 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

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

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

China enacts Anti-Foreign Sanctions Law

On 10 June 2021, the Standing Committee of the National People’s Congress of the PRC enacted the Anti-Foreign Sanctions Law (AFSL), which took effect on the same date. The AFSL follows previous measures taken by the PRC government, including the sanctions announced by the PRC Ministry of Foreign Affairs (MOFA) against foreign individuals and organisations, … Read more

Biden Administration Replaces “Communist Chinese Military Company” Sanctions with “Chinese Military-Industrial Complex” Sanctions

Over the past few days, the US government has issued additional guidance and substantially revised prior guidance related to its sanctions against certain Chinese companies. As discussed in our previous post, Executive Order (“EO“) 13959, dated November 12, 2020, targets “Communist Chinese Military Companies” (“CCMC“) by prohibiting “any transaction in publicly traded securities, or any securities … Read more