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

OFAC Issues Sanctions in Response to Belarus’s Forced Diversion of a Ryanair Flight

On June 21, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated sixteen individuals and five entities pursuant to Executive Order (“E.O.”) 13405 of June 16, 2006, entitled “Blocking Property of Certain Persons Undermining Democratic Processes or Institutions in Belarus.” According to a press release, OFAC designated these individuals and … Read more

New Commission opinion on EU sanctions and “making available”: the impact of a non-sanctioned company and its subsidiaries of having a Designated Person director

On 8 June 2021, the European Commission published an opinion on Article 2(2) of Council Regulation (EU) No 269/2014 of 17 March 2014 (the “Regulation”). The Regulation imposes an asset freeze on certain Russian individuals and entities in response to the situation in Ukraine. Article 2(2) contains the standard EU asset freeze wording providing that “no funds or economic … Read more

US Treasury publishes new Myanmar sanctions regulations

On Friday 28 May, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued the Burma Sanctions Regulations (the Regulations) in relation to the implementation of Executive Order 14014, “Blocking Property with Respect to the Situation in Burma.” The Regulations, which come into effect on 1 June, 2021, provide a framework, consistent … 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

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

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

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