OFAC Reaches Settlement with Alfa Laval Subsidiaries Over Iran Referral

On July 19, 2021, the Treasury Department’s Office of Foreign Assets Control (OFAC) announced that it had entered into settlement agreements with two subsidiaries of Alfa Laval AB, the UAE-based Alfa Laval Middle East Ltd. (“AL Middle East”) and the US-based Alfa Laval Inc. (“AL US”) to settle apparent violations of the Iranian Transactions 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

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

Jonathan Cross recently featured in Anti-Corruption Report

Jonathan Cross recently published “Managing Sanctions Risk Up and Down the Supply Chain” in the Anti-Corruption Report. The article looks at the importance of companies ensuring their sanctions compliance procedures address “supply-chain” risks, given the increase in actions brought by The US Treasury Department’s Office of Foreign Assets Control (OFAC); where the subject was one … 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

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