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

The U.S. Establishes a New Ethiopia Sanctions Regime

On September 17, 2021, the President signed Executive Order (“E.O.”) 14046, imposing sanctions on certain persons with respect to the humanitarian and human rights crisis in Ethiopia. According to a Fact Sheet issued by the White House, the conflict in Ethiopia “has sparked one of the worst humanitarian and human rights crises in the world, … Read more

OFAC Enters Settlement Agreement With a U.S. Company Related to Certain Exports to Iran Through Non-U.S. Distributors

On September 9, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) entered a settlement agreement with NewTek, Inc. (“NewTek”), headquartered in San Antonio, Texas. According to a press release, NewTek agreed to pay $189,483 to settle its potential civil liability for 52 apparent violations of the Iranian Transactions and Sanctions … Read more

OFAC Sanctions Cryptocurrency Exchange to Combat Ransomware Payments, Releases New Ransomware Guidance

On September 21, 2021, the Office of Foreign Assets Control (“OFAC”) of the Treasury Department issued an Updated Advisory on Potential Sanctions Risks for Facilitating Ransomware Payments (“Updated Advisory”), which warns of the sanctions risks of making or facilitating ransomware payments and provides expanded guidance on steps that companies may take to mitigate ransomware risk. … Read more

Companies May Risk Violating U.S. Sanctions Against the Taliban by Conducting Business With the Government of Afghanistan

Now that the Taliban controls Afghanistan, many businesses with economic interests or investments in the country are reevaluating potential sanctions risks. Indeed, a former OFAC official explained that, “[t]his is a new world,” and that he could not “think of any case in which a terrorist group that’s already designated became the power in charge … Read more

Designated: A Sanctions Podcast EP2: History of US Sanctions Under the JCPOA May Offer Insight to Terms of Renewed JCPOA Participation

In this episode, Jonathan Cross, Brittany Crosby-Banyai and Dan Hudson discuss the history of the Iran sanctions program under the Iranian nuclear deal, known as the Joint Comprehensive Plan of Action (“JCPOA”). They also analyze the mechanisms by which sanctions were re-imposed when the US left the agreement. These considerations offer insight as to the … Read more

OFAC Enters Settlement Agreement With a Non-U.S. Company, and its U.S. Parent Company, Related to Violations of Iran and Syria Sanctions

On August 27, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) entered a settlement agreement with First Bank SA (“First Bank”), located in Romania, and its U.S. parent company, JC Flowers & Co. (“JC Flowers”). According to a press release, the companies agreed to pay $862,318 to settle potential civil … Read more

UK, US and Canada impose additional sanctions on Belarus

On 9 August 2021, the UK, US and Canadian governments announced the imposition of additional sanctions on Belarus. These new measures follow the coordinated imposition of sanctions against Belarus by the EU, UK, Canada and the US in June 2021. The new US measures involve, among other restrictions: new US secondary sanctions applicable to companies … Read more

OFAC settlement with online payment-services company highlights key OFAC expectations in sanctions compliance programs

On July 23, 2021, the Office of Foreign Assets Control (OFAC) of the US Department of the Treasury entered a settlement agreement with an online payment-services company business based in New York, Payoneer Inc. (Payoneer). Payoneer, which went public on the Nasdaq exchange in June 2021, provides digital payment services and online money transfer services … Read more