Designated by D.C.: How U.S. Sanctions Combat Foreign Corruption

June 16, 2017
By: Saskia Rietbroek, Principal SanctionsAlert.com and Anna Sayre, Legal Content Writer,www.SanctionsAlert.com

The use of sanctions as an international means of effecting change has grown exponentially in recent times. As countries become less and less keen to use military force, the world has turned to sanctions implementation as a means of affecting international change, both politically and socially. (more…)

Between a rock and a hard place: How to ensure sanction compliance when operating a facility in a sanctions-targeted country

June 13, 2017
By Simon Hirsbrunner and Alice Lauterjung

The recently reported resignation of cement manufacturer LafargeHolcim’s CEO has thrown a spotlight on the risks of operating commercial activities in countries targeted by economic sanctions. [1] Without drawing any conclusions on the legal qualification of LafargeHolcim’s conduct in the specific circumstances, the following provides an overview of the principal issues at stake in this case. (more…)

Trump Sanctions Policies Still Undefined, But Could Affect Many Nations and Compliance Officers – Part 6: Treasury Secretary Steven Mnuchin’s Conciliatory Commitment to the Status Quo, For the Most Part

June 3, 2017
By: Anna Sayre, Legal Content Writer, SanctionsAlert.com

In this series, we present the comments and assertions made by President Donald Trump and his top assistants concerning economic sanctions and export controls so that compliance professionals can make informed decisions as to the likely positions of the new U.S. administration in the next four years. (more…)

Increasingly Complex Iranian Sanctions Regimes Cause Ongoing Complications for Compliance Suites

May 17, 2017
By: Anna Sayre, Legal Content Writer, SanctionsAlert.com

Since the international community decided to implement a plan to reduce sanctions against Iran, formally known as the Joint Comprehensive Plan of Action (JCPOA), on January 16, 2016 (“Implementation Day”), the European and U.S. regimes have become increasingly misaligned. Not surprisingly, this has led to compliance officers and other professionals having to navigate extremely treacherous waters. In a recent poll conducted by Sanctions Alert, when attendees were asked what the prospects are that U.S. sanctions will be eased in the near future, almost 90% of those polled indicated that this was either “Unlikely” or “Very Unlikely”. (more…)

OFAC New Delisting ‘FAQs’ Only Provide Part of the Wider Picture regarding Removal of SDN Designation

May 2, 2017 [updated May 16, 2017]
By Anna Sayre, Legal Content Writer, SanctionsAlert.com

On April 20, 2017, the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a new page of frequently asked questions (FAQs) regarding petitions for removal of Specially Designated Nationals (SDNs) from OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List). (more…)

Trump Administration Certifies Iran’s Compliance with Nuclear Deal, but Initiates Review of Sanctions Relief

April 21, 2017
By: Anthony Rapa*

Will the Trump Administration “waive” goodbye to sanctions relief under the Iran nuclear deal?

Last night, Secretary of State Rex Tillerson certified to Congress that Iran is in compliance with the Joint Comprehensive Plan of Action (JCPOA) agreement regarding Iran’s nuclear program, but signaled that the Trump Administration is reviewing whether continued sanctions relief under the JCPOA would be appropriate.  Secretary Tillerson’s communication is set out in a letter to House Speaker Paul Ryan and summarized in a Reuters article. (more…)