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On February 18, 2021, the Biden Administration rescinded the United States’ re-imposition of United Nations sanctions against Iran, which were lifted as part of the Iran nuclear deal known as the Joint Comprehensive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

Myanmar Sanctions Tracker

We are closely monitoring the international response to the evolving political situation in Myanmar and will be 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 … Read more

Update on Recent Developments in Myanmar

Political developments in Myanmar this week raise the prospect of the possible reintroduction of sanctions against the country. International businesses with operations or investments in Myanmar should be aware of the potential for sanctions or other measures to be implemented at short notice and consider how their business may be impacted and the steps that … 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

EU introduces global human rights sanctions regime

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

OFSI Releases its Third Annual Review for 2019-2020

On October 9, 2020, HM Treasury’s Office of Financial Sanctions Implementation (OFSI) published its latest Annual Review for the 2019-20 financial year. Established in 2016, OFSI is a component of Her Majesty’s Treasury, which implements and enforces financial sanctions in the UK. The publication marks the third report which OFSI have published and provides an … Read more

OFAC Sanctions Russian Government Research Institution Connected to the Triton Malware

On October 23, OFAC designated State Research Center of the Russian Federation FGUP Central Scientific Research Institute of Chemistry and Mechanics (TsNIIKhM) to OFAC’s Specially Designated Nationals and Blocked Persons List because of TsNIIKhM’s involvement with Triton malware. TsNIIKhM is a Russian government-controlled research institution. OFAC’s press release is available here. The 2017 Triton Malware … Read more

OFAC Issues Finding of Violation—but No Penalty—for Sanctions Violations Caused by Compliance System Defects and Human Error

On April 30, 2020, the US Department of Treasury (“Treasury”)’s Office of Foreign Assets Control (“OFAC”) issued a Finding of Violation to American Express Travel Related Services Company (“AMEX”). AMEX issued a prepaid travel card to Gerhard Wisser, a specially designated national or “SDN,” and subsequently processed approximately $35,000 in transactions Wisser conducted using the card. AMEX … Read more