1. An Update on Economic Sanctions Related to Events in Ukraine

  2. EU imposes sanctions on 21 politicians and military officers from Russia and Crimea

    Includes a list of names…

  3. Compliance with OFAC regulations is crucial from a business, financial and reputational-risk perspective.

    — Complying with Economic Sanctions Is Critical to Businesses

  4. The Gloves are Off: U.S. Sanctions Block Aggressors in Crimea

    Read on»

  5. Preliminary reports on the impact of the JPOA indicate that the Iranian oil industry has already benefited from the sanctions relief. The International Energy Agency said that Iran exported a daily average of 1.32 million barrels of crude oil in January 2014. This number is far higher than the agreed-upon daily limit of 1 million barrels.

    — A Crude Bargain: Temporary Relaxation of U.S. Sanctions for the Iranian Petroleum Industry

  6. Given geopolitical considerations, it is unlikely the United States will impose broad sanctions on Russia or Russian entities. However, as we have seen in other crises, events can move swiftly and companies doing business in Ukraine (and perhaps Russia as well) should at least be considering their worst-case-scenario contingency plans.

    — Attorney Jonathan Epstein of Holland & Knight in Crisis in Ukraine: U.S. Imposes Targeted Sanctions

  7. BNP is only the latest in a string of foreign banks that have agreed to pay billions in fines when faced with increasingly aggressive US regulators seeking to punish Iran for its nuclear program.

    — French Bank Sets Aside Over $1 Billion for US Sanctions Violations

  8. Companies doing business in Russia and Ukraine should monitor closely any measures imposed pursuant to this EO and congressional action to ensure compliance. Penalties for noncompliance are severe.

    — Attorneys from White & Case on President Obama’s executive order targeting those contributing to the situation in Ukraine.

  9. Fast Developing Events in Ukraine Prompt EU and US Trade Sanctions

[T)he European Union published a regulation imposing sanctions on several specific Ukrainian persons, including the former president of Ukraine, Viktor Yanukovych.  In addition, President Obama signed an executive order authorizing the imposition of U.S. sanctions in connection with the situation in Ukraine.

Read more»

    Fast Developing Events in Ukraine Prompt EU and US Trade Sanctions

    [T)he European Union published a regulation imposing sanctions on several specific Ukrainian persons, including the former president of Ukraine, Viktor Yanukovych.  In addition, President Obama signed an executive order authorizing the imposition of U.S. sanctions in connection with the situation in Ukraine.

    Read more»

  10. EU responds to Ukrainian crisis by imposing asset freeze on 18 politicians, family members and businessmen

    Read more»

  11. Despite virtually total blanket sanctions against Iran dating back to 1995, one exception beginning in 2010 has been for personal communications over the Internet, in response to the Iranian government’s repression of dissidents. The intent of the rule was to foster the free flow of information to Iranian citizens. […] GL D-1 now amends, clarifies and expands the license for personal communications over the Internet with persons in Iran.

    — Attorneys Burt Braverman and Jennifer Frewer of Davis Wright Tremaine on the recently expanded license for exporting personal communications items and services to Iran.

  12. Given the limited scope and duration of the sanctions relief, the substantial complexity of the sanctions regime that remains in place, and the uncertainty regarding the prospects for a long-term agreement, it is advisable for anyone seeking to pursue potential new business opportunities based on the recent U.S. Guidance to exercise caution.

    — Attorneys from  K&L Gates on what the Iran sanctions relief means for businesses in the Middle East.

  13. OFAC guidance on the [Foreign Sanctions Evaders] list clearly indicates that there is no “grandfathering” allowance for transactions initiated prior to the listing of an FSE. Where a potential transaction is in process at the time of a listing, U.S. persons are required to terminate and/or cease dealings with the FSE-listed party immediately unless and until otherwise exempted or specifically licensed by OFAC.

    — Attorneys Rebekah Marie Jones and Wynn Segall of Akin Gump on the Office of Foreign Assets Control’s Foreign Sanctions Evaders List.

  14. U.S. persons are generally prohibited from all transactions or dealings, direct or indirect, involving persons or entities identified on the [Foreign Sanctions Evaders] List related to any goods, services, or technology (i) in or intended for the United States, or (ii) provided by or to U.S. persons, wherever located.

    — Attorney Rich Matheny of Goodwin Procter on the Office of Foreign Assets Control’s new Foreign Sanctions Evaders List

  15. While the majority of this year’s actions focused on Iran, OFAC continued to announce a number of designations made under the other US sanctions programs, including those targeting terrorism, transnational criminal organizations, and narcotics traffickers. OFAC also announced a handful of settlements stemming from apparent sanctions-related violations…

    — Attorneys from Shearman & Sterling on the interim agreement with Iran; enforcement actions against Weatherford, Royal Bank of Scotland, and HSBC; and other sanctions-related developments in Q4 of 2013.