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…)

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…)

Record-breaking 1.19 Billion Fine for Chinese Tech Giant Demonstrates Broad Extraterritorial Reach of U.S. Export Control Laws

March 22, 2017
By Anna Sayre, Legal Content Writer SanctionsAlert.com

On March 7, three U.S. regulators – the Department of Treasury’s Office of Foreign Assets Control (OFAC), the Department of Commerce’s Bureau of Industry and Security (BIS), and the Department of Justice (DOJ) – entered into a coordinated settlement with Zhongxing Telecommunications Equipment Corporation (ZTE), in which the company agreed to a record-breaking combined $1.19 billion in civil and criminal penalties for knowingly shipping illegal telecommunications equipment to Iran and North Korea in violation of U.S. sanctions law. ZTE, a Chinese publicly traded telecommunications manufacturer, is the largest in China and the fourth largest telecommunications manufacturer in the world. (more…)

OFAC Issues General License Effectively Lifting Sudan Sanctions

February 3, 2017
By: Michelle Turner Roberts, Dan Fisher-Owens, Ben Flowe, Perry Bechky, Babak Hoghooghi, Ray Gold, John Ordway, and Jason McClurg*

With a stroke of his pen on January 13, 2017, by Executive Order 13761, President Obama effectively lifted the Sudan Sanctions, in recognition of the Government of Sudan’s progress in reducing offensive military action, improving humanitarian access, and cooperating with the United States in counter-terrorism efforts. (more…)