What to Expect for Economic Sanctions Under President Trump?

January 13, 2017
By Anthony Rapa, Alexis Early and Peter Jeydel*

President-elect Trump has made bold and surprising pronouncements about what he may do after January 20 in the field of international affairs, and these foreign policy choices are likely to have a significant impact on the future course of U.S. economic sanctions programs targeting Iran, Cuba, Russia and other areas. Mr. Trump has said he would terminate the Iran nuclear deal, and with it the sanctions rollback that has taken place over the past year, although actually convincing the rest of the world to re-impose sanctions on Iran would be a monumental feat of diplomacy.  On Cuba, Mr. Trump has given reasonably clear signals both that he would support the recent easing of sanctions and that he would reverse it, so the actual policy of the incoming Administration is hardly better than a 50/50 guess at this stage, though with the odds slightly favoring some tightening of sanctions.  Russia may be different.  That is one area in which Mr. Trump’s statements and actions point to a real possibility of a wholesale change in U.S. policy, although bipartisan congressional concerns with Russia may present a major obstacle to radically changing the current state of affairs, at least without significant concessions by Russia. (more…)

Primer on agencies that enforce US sanctions: State agencies and regulators

November 3, 2016
By Anna Sayre, Legal Content Writer, SanctionsAlert.com

The US has one of the most complex national systems of sanctions enforcement in the world. This system derives from the number of agencies that are empowered to initiate actions against violators of US sanctions. Because each US agency maintains a different “Do Not Touch” list, organizations and individuals on the various lists may differ. Furthermore, the regulations issued by these various agencies often have areas of overlap. It is not uncommon for three or four US agencies to take action jointly, thus exposing a business to multiple investigations and varying penalties. (more…)

Sanctions: Brainteasers With Serious Consequences

By: Davina Given*

Failure to comply with financial sanctions carries serious penalties, most notably in the US, where banks have collectively paid billions of dollars in fines.  Even in the UK, a failure to comply with sanctions carries the potential for unlimited criminal and regulatory fines and/or imprisonment.  Yet financial sanctions are often difficult for most businesses to grapple with, particularly if they do not have the resources of the very largest businesses.  Political imperatives may lead to the imposition of financial sanctions in respect of existing, longstanding business.  Individual targets may change quickly and abruptly, with little fanfare.  Different countries involved in a transaction may apply slightly different financial sanctions, so that the transaction may be legal in one country but illegal in another.  Yet on top of those issues, there is a further legal difficulty: what does any particular financial sanction actually prevent? (more…)

Primer on agencies that enforce US sanctions: The Department of Homeland Security

September 18, 2016
By Anna Sayre, Legal Content Writer, SanctionsAlert.com

The US has one of the most complex national systems of sanctions enforcement in the world. This system derives from the number of agencies that are empowered to initiate actions against violators of US sanctions. Because each US agency maintains a different “Do Not Touch” list, organizations and individuals on the various lists may differ. Furthermore, the regulations issued by these various agencies often have areas of overlap. It is not uncommon for three or four US agencies to take action jointly, thus exposing a business to multiple investigations and varying penalties. (more…)