John B. Reynolds

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

In the latest development in the complex and evolving sanctions targeting the Government of Venezuela, on September 9, 2019, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued General License (“GL”) 34,  The new GL authorizes transactions involving certain individuals that would otherwise be prohibited…
Continue Reading New General License Reinforces Broad Scope of Sanctions Against the Government of Venezuela

The Department of Commerce added 46 more non-U.S. affiliates of Huawei Technologies Co., Ltd. to the Bureau of Industry and Security (BIS) Entity List, joining Huawei and 68 of its non-U.S. subsidiaries that were put on the list in May.  The Commerce Department also extended a temporary general license permitting…
Continue Reading Davis Polk Client Memorandum: Commerce Department Extends Huawei General License, Adds More Huawei Affiliates to Entity List

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…
Continue Reading Davis Polk Client Memorandum: United States Imposes Blocking Sanctions on the Government of Venezuela

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…
Continue Reading Davis Polk Client Memorandum: Second Round of Sanctions on the Russian Federation under Chemical and Biological Weapons Control and Warfare Elimination Act

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…
Continue Reading New Economic Sanctions on Iran: More Sound than Fury

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…
Continue Reading U.S. Government Takes Aim at China With Entity List Additions and New Executive Order

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…
Continue Reading Bank Secrecy Act Reform Legislation Advanced Unanimously by House Financial Services Committee

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…
Continue Reading U.S. Expands Sanctions Targeting Iran’s Metals Sector

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…
Continue Reading OFAC Publishes Guidance on Sanctions Compliance Programs

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…
Continue Reading U.S. Department of State to Cancel Iranian Oil Waivers