Sanctions

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By Thaddeus McBride & Reid Whitten

Under a recent court decision, UK government agencies may be able to shield the names of British companies transacting in Iran, and thereby aid these companies in averting potential consequences of U.S. law.
 Continue Reading Mind Your Own Businesses: UK Court Decision May Signal Pushback On Extraterritorial Enforcement of US Trade Laws

By Thaddeus McBride, Mark Jensen, & Corey Phelps

In late September, Flowserve Corporation (“Flowserve”) and a number of its subsidiaries agreed to settle alleged export violations with the Department of Commerce, Bureau of Industry of Security (“BIS”) for $2.5 million, and to remit $502,408 to the U.S. Department of the Treasury, Office of Foreign Assets Control (“OFAC”) to settle alleged U.S. sanctions violations. Flowserve, including its subsidiaries, is an oil, gas, and chemical services company with operations around the world. The settlement underscores the value of compliance measures specifically tailored to a company’s operations, and provides yet another example of the U.S. government vigorously enforcing U.S. law overseas.
 Continue Reading OFAC, BIS Double Up Flow Serve: What the Flowserve Settlement Says About Corporate Compliance Programs

By Thaddeus McBride & Mark Jensen

On August 25, 2011, a major U.S. financial institution agreed to pay the U.S. Department of Treasury, Office of Foreign Assets Control (“OFAC”) $88.3 million to settle claims of violations of several U.S. economic sanctions programs. While OFAC settlements with financial institutions in recent years have involved larger penalty amounts, this August 2011 settlement is notable because of OFAC’s harsh—and subjective—view of the bank’s compliance program.
 Continue Reading OFAC Settles Alleged Sanctions Violations for $88.3 million

By Thaddeus McBride , Reid Whitten & Corey Phelps

On August 18, 2011, based on the “continuing escalation of violence against the people of Syria,” President Barack Obama issued Executive Order 13582 (“EO 13582”) to expand significantly U.S. sanctions on Syria.  This briefing summarizes those sanctions as well as the General Licenses issued—first on August 18 and again on September 9—by the U.S. government to authorize limited transactions with Syria.
 Continue Reading Syria Update: Significant New Sanctions Imposed

By Scott Maberry, Thad McBride, Mark Jensen, and Corey Phelps

In recent weeks, the U.S. Department of Treasury, Office of Foreign Assets Control (“OFAC”) has updated the sanctions regulations it administers against Libya and North Korea. These recently implemented sanctions continue OFAC’s trend towards precise, targeted sanctions; moreover, the way in which OFAC amended its sanctions on North Korea could have implications for U.S. sanctions on Cuba.
 Continue Reading Trading Up: Newly Implemented North Korea and Libya Sanctions

By Curtis M. Dombek

On February 25, 2011, the President issued an Executive Order blocking not only the assets of Muammar Qadhafi, Ayesha Qadhafi, Khamis Qadhafi, Mutassim Qadhafi, and Saif Al Islam Al Qadhafi, but also blocking all assets of the Government of Libya, as follows:
 

“All property and interests in property that are in the United States, that hereafter come within the United States, or that are or hereafter come within the possession or control of any United States person, including any overseas branch, of the Government of Libya, its agencies, instrumentalities, and controlled entities, and the Central Bank of Libya, are blocked and may not be transferred, paid, exported, withdrawn, or otherwise dealt in.”
 Continue Reading New Sanctions Block Continuing Performance Of Libyan Government Contracts In Addition To Targeting Col. Qadhafi’s Assets

By John W. Chierichella and Jessica M. Madon

As a follow-up to our previous blog article, available here, we provide this month a more in depth analysis of some of the key features of the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (“CISADA”) passed July 1, 2010. Our focus this month is on the expansion of the types of activities and persons that may be sanctioned. We also address the new mandatory representation and certification for government contractors. Finally, we note that the EU and Canada have imposed similar sanctions against Iranian transactions and we provide a brief synopsis of those sanctions.
 Continue Reading Comprehensive Iran Sanctions, Accountability, And Divestment Act Of 2010 – The Expanded Categories Of Sanctionable Activities