Wake Up To Sanctions

SanctionsAlert.com Sanctions Round Up
November 17, 2017

EU removes FARC from terrorist list; imposes first set of sanctions on Venezuela

On November 13, 2017, the E.U. removed Colombian guerilla group FARC from its terrorism sanctions list following its disarmament and re-launch as a political party. Earlier, in September 2016, the E.U.had suspended its terrorism sanctions on FARC in recognition of the peace agreement signed between FARC and the Colombian government.

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OFAC Enforcement Actions By the Numbers: What Makes a Penalty?

Cuba, Iran, Sudan Top the List of OFAC Actions; Recent Trend Suggests Voluntary Disclosure Could Mitigate Penalty Amount

November 7, 2017
By Anna Sayre, SanctionsAlert.com

The dread of an OFAC penalty is something that no institution or company wants to face. But the Iran and Cuba sanctions regimes are more frequently enforced than others. The amount of sanctions enforcement cases based on violations of these two programs dwarfs any others by a wide margin. And, once you find out that your company has made a sanctions misstep, and you tell OFAC about it, you may mitigate the penalty amount.Since 2013, the benefits of voluntary disclosure have begun to show as part of a downward trend. (more…)

OFAC Enforcement Actions By the Numbers: Who’s At Risk?

Recent Up Tick in Number of OFAC Enforcement Actions against IT/telecom, Offshore Services; California, New York and Texas Companies Most At Risk

October 20, 2017
By Anna Sayre, SanctionsAlert.com

Are you a business that thinks OFAC only takes action against New York-based financial institutions? Think again.

Since 2014, OFAC enforcement actions have significantly increased against non-financial institutions, particularly in IT/telecom and offshore services industries. Furthermore, in addition companies in New York, those in Texas, and especially California, remain highly at risk. (more…)

OFAC Shortens New Debt Maturity Periods under Russian Financial and Energy Sectoral Sanctions

By Peter Jeydel on September 29, 2017

OFAC today revised its Ukraine/Russia-related sectoral sanctions directives prohibiting US person dealings in new debt or new equity of listed Russian financial institutions and new debt of listed Russian energy companies (in both cases, these prohibitions continue to apply to the “interests in property” of the listed entities, meaning any entity 50% or more owned by them). OFAC took this step pursuant to a statutory mandate in the Countering Russian Influence in Europe and Eurasia Act of 2017 (CRIEEA).  See our advisory on CRIEEA.  The changes made today are as follows (and as expected based on the statutory mandate): (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…)