Mr. Schisa is counsel in Davis Polk’s Financial Institutions Group and economic sanctions and national security practice. [Full Bio]

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

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
Continue Reading U.S. Government Targets “Three Stooges of Socialism” with New Measures Against Cuba, Venezuela, and Nicaragua

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
Continue Reading CFIUS Imposes $1 Million Civil Monetary Penalty for Breach of Mitigation Agreement

On April 8, 2019, the U.S. State Department announced its intent to designate Iran’s Islamic Revolutionary Guard Corps (“IRGC”) as a Foreign Terrorist Organization (“FTO”) under section 219 of the Immigration and Nationality Act, 8 U.S.C. § 1189.  The designation will take effect upon publication in
Continue Reading U.S. Government Adds to Sanctions Against the IRGC with Unprecedented FTO Designation

On March 4, 2019, the U.S. State Department announced that, for the first time, it would permit actions under Title III of the Cuban Liberty and Democratic Solidarity (Libertad) Act of 1996, Pub. L. 104-114 (the “Libertad Act”), which authorizes U.S. nationals that own claims to property
Continue Reading In Unprecedented but Mostly Symbolic Move, State Department Allows Some Claims under Title III of the Libertad Act

On January 28, 2019, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) sanctioned Petroleos de Venezuela S.A. (“PdVSA”), Venezuela’s state-owned oil company, pursuant to Executive Order (“E.O.”) 13850 for operating in the oil sector of the Venezuelan economy, following a determination by the Secretary
Continue Reading OFAC Designates PdVSA

As 2018 came to a close, U.S. financial regulators continued to pursue anti-money laundering (“AML”) enforcement actions against financial institutions, announcing monetary penalties against and resolutions with three U.S. broker-dealers.  The Financial Crimes Enforcement Network (“FinCEN”), the Securities and Exchange Commission (“SEC”) and the
Continue Reading U.S. Regulators Announce BSA/AML Enforcement Actions Against U.S. Broker-Dealers

On December 19, 2018, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced its plan to lift sanctions on three Russian entities for agreeing to distance their businesses from a prominent oligarch.  Specifically, OFAC informed Congress of its intention to terminate sanctions on entities previously designated for
Continue Reading OFAC Announces Intent to Delist Rusal and Other Entities Owned by Sanctioned Oligarch Deripaska