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

OFSI updates its guidance on the imposition of monetary penalties

The Office of Financial Sanctions Implementation (“OFSI”) published an updated version of its “Monetary penalties for breaches of financial sanctions – guidance” (the “Guidance”) on 10 March 2021. The updated Guidance comes into force on 1 April 2021. Any breaches reported to OFSI after this date will be dealt with under the new guidance. OFSI … Read more

US Court Provides Relief from Chinese Military Company Designation

As widely reported in the press this week, leading Chinese smartphone manufacturer Xiaomi Corporation has successfully appealed to the US federal judiciary against its designation as a Communist Chinese Military Company (CCMC), thus avoiding the broad-ranging export and investment restrictions implicated by this designation. In this post we examine the judgment of the US District … Read more

The US Imposes Additional Sanctions in Response to the Myanmar Coup

On March 10, 2021, the US imposed additional sanctions related to the February 1, 2021 coup in Myanmar (“Coup”), pursuant to Executive Order (“EO”) 14014. In a press release, OFAC stated that it sanctioned the two adult children of the commander-in-chief of the Myanmar military forces, as well as six entities that are owned or … 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