Mr. Reynolds is a partner in Davis Polk’s Financial Institutions Group and the economic sanctions and national security practice. [Full Bio]

Late on the evening of August 5, 2019, President Trump issued a new Executive order imposing blocking sanctions on the Government of Venezuela (“GoV”).  The order builds on prior limited sanctions imposed on the GoV, as well as blocking sanctions imposed on certain GoV agencies and state-owned companies
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On August 3, 2019, the U.S. Department of State and the Department of the Treasury announced a second round of sanctions on the Russian Federation pursuant to the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (CBW Act) in response to Russia’s involvement in a
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On June 24, 2019, President Trump signed an Executive Order (“EO” or “Order”) imposing new economic sanctions on the Supreme Leader of Iran, Ayatollah Ali Khamenei, and the Iranian Supreme Leader’s Office. The EO blocks all of the Supreme Leader’s property and interests in property in the United States, that
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On May 21, 2019, the Department of Commerce published a final rule adding Huawei Technologies Co. Ltd and 68 of its non-U.S. affiliates located in 26 countries (collectively, “Huawei”) to the Bureau of Industry and Security’s (“BIS”) Entity List.  Commerce had previously announced its intention
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The House Financial Services Committee unanimously recommended to the full House on May 9, 2019 a bill that would reform the U.S. anti-money laundering (AML) regime.  H.R. 2514, the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act of 2019 (the COUNTER Act), would amend the Bank Secrecy Act
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On May 8, 2019, the one-year anniversary of his decision to end the United States’ participation in the Joint Comprehensive Plan of Action (“JCPOA”) with Iran, President Trump issued a new Executive Order “Imposing Sanctions with Respect to the Iron, Steel, Aluminum, and Copper Sectors of Iran” (the
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On May 3, 2019, the Treasury Department’s Office of Foreign Assets Control (“OFAC”) published A Framework for OFAC Compliance Commitments (the “Compliance Framework”), a guidance document that sets forth OFAC’s views of the essential elements of an effective economic sanctions compliance program (“SCP”).  OFAC
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On April 22, 2019, Secretary of State Mike Pompeo announced that the waivers issued to China, Greece, India, Italy, Japan, South Korea, Taiwan and Turkey, which allow them to continue to import Iranian oil after the United States fully reinstated secondary sanctions against Iran last fall, will expire on May
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In separate statements on April 17, 2019 coinciding with the anniversary of the Bay of Pigs invasion, U.S. Secretary of State Mike Pompeo and National Security Adviser John Bolton announced several measures intended to increase pressure on Cuba, Venezuela, and Nicaragua, in response to corruption, human rights abuses, and political
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The Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”) recently publicly announced that it had imposed a $1 million civil monetary penalty against an undisclosed entity for repeated violations of its 2016 mitigation agreement with CFIUS, including failure to establish requisite security
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