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

Recently, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced technical changes to the regulations implementing Treasury-administered economic sanctions on North Korea and new inflation-adjusted civil monetary penalties.

1. North Korea Economic Sanctions

On December 20, 2019, President Donald Trump signed into law the Otto Warmbier North Korea
Continue Reading OFAC Makes Technical Changes to North Korea Sanctions and Civil Monetary Penalty Regulations

The U.S. Department of the Treasury recently released a proposed rule to impose a filing fee for certain CFIUS transactions. If enacted, the proposed filing fee would raise strategic considerations for parties intending to submit a transaction for CFIUS review. Our visual memo discusses this proposal in greater detail.

Continue Reading Proposed Rule: Filing Fees for Certain CFIUS Transactions

On February 18, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) imposed blocking sanctions pursuant to Executive Order (“E.O.”) 13850 against Rosneft Trading, S.A. (“RTSA”) and its president and board chairman, Didier Casimiro.  According to the press release announcing the designation,
Continue Reading OFAC Targets Russian Support for Maduro Regime with New Sanctions Designations

On January 13, 2020, the U.S. Treasury Department promulgated its final regulations implementing the Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA) to reform the authority and jurisdiction of the Committee on Foreign Investment in the United States (CFIUS). The final regulations were released in two parts: one addressing
Continue Reading CFIUS Issues Final FIRRMA Regulations

On January 10, 2020, President Trump issued Executive order 13902 (“E.O. 13902”) which authorizes the U.S. Department of the Treasury to impose additional sanctions targeting the construction, mining, manufacturing and textiles sectors of the Iranian economy, as well as any other sector of the Iranian economy subsequently specified by the
Continue Reading “Maximum Pressure” to the Max: United States Sanctions Additional Sectors of Iran’s Economy

On November 27, 2019, the United States Department of Commerce issued an advance notice of proposed rulemaking seeking public comment on “regulations that would govern the process and procedures that the Secretary of Commerce will use to identify, assess, and address certain information and communications technology and services transactions that
Continue Reading U.S. Department of Commerce Proposes Rule Governing Information and Communications Technology and Services

On October 23, 2019, the Treasury Department’s Office of Foreign Assets Control (“OFAC”) acting at the direction of President Trump and in consultation with the State Department, lifted sanctions on three Turkish government ministers and two Turkish government ministries and removed them from the List of Specially Designated
Continue Reading OFAC Lifts Short-Lived Turkey Sanctions

On October 14, 2019, President Trump issued an Executive order authorizing sanctions targeting the Turkish government in connection with its military operations in northern Syria. The U.S. government also announced a 50% tariff on imports of steel from Turkey and cancellation of trade agreement negotiations.

The initial sanctions announced by
Continue Reading Davis Polk Client Memorandum: United States Sanctions Turkish Government over Syrian Incursion

In response to what Treasury Secretary Steven Mnuchin called “Iran’s brazen attack against Saudi Arabia,” and following President Trump’s tweet ordering Treasury to “substantially increase Sanctions on the country of Iran,” today the Treasury Department’s Office of Foreign Assets Control (OFAC) imposed additional sanctions on the Central Bank of Iran
Continue Reading U.S. Imposes Additional Sanctions on Central Bank of Iran

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