Economic Sanctions

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Financial services regulatory reform in 2018 is complex and evolving. To assist in navigating this landscape, we have prepared a reference tool that provides context and summarizes current developments across a range of key regulatory areas, agencies and actors.  We will continue to track these issues and provide updated versions … Read More

On May 8, 2018, President Trump announced that he was terminating the United States’ participation in the Joint Comprehensive Plan of Action (“JCPOA”) with Iran and issued a National Security Presidential Memorandum (“NSPM”) directing his administration to immediately begin the process of fully re-imposing sanctions that … Read More

On May 1, 2018, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued two amended Ukraine/Russia related General Licenses (“GLs”): GL 12B, “Authorizing Certain Activities Necessary to Maintenance or Wind Down of Operations or Existing Contracts” and GL 13A, “Authorizing Certain … Read More

Citing the Russian government’s “range of malign activities around the globe,” on April 6, 2018, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) sanctioned seven Russian oligarchs and 12 companies they own or control, 17 senior Russian government officials, and a state-owned … Read More

Financial services regulatory reform in 2018 is complex and evolving. To assist in navigating this landscape, we have prepared a reference tool that provides context and summarizes current developments across a range of key regulatory areas, agencies and actors.  We will continue to track these issues and provide updated versions … Read More

The Trump Administration has officially banned U.S. transactions in Venezuela’s controversial “petro” digital currency.  On March 19, 2018, the Trump Administration issued a new Executive Order, “Taking Additional Steps to Address the Situation in Venezuela” (the “Digital Currency E.O”), which prohibits U.S. persons and others subject to … Read More

For the first time in 30 years, Congress may expand the jurisdiction of the Committee on Foreign Investment in the United States (“CFIUS”).  In testimony before the Senate Banking Committee on January 25, 2017, three Administration officials expressed support for the Foreign Investment Risk Review Modernization Act of … Read More

Following on last week’s hearing in which it heard testimony from private sector representatives, the Senate Banking Committee continued its consideration of possible reforms to the U.S. anti-money laundering (“AML”) and countering the financing of terrorism (“CFT”) framework with a January 17, 2018 hearing in which … Read More

Despite his long-held stance that it is one of the worst deals ever, today President Trump again executed the necessary waivers to continue the United States’ nuclear sanctions relief to Iran in compliance with the Joint Comprehensive Plan of Action (the “JCPOA”).  The President made clear in a statement, … Read More

On October 13, 2017, President Trump announced that he would not make a quarterly certification required by the Iran Nuclear Agreement Review Act (“INARA”) because he was unable to certify that the provision of sanctions relief to Iran under the Joint Comprehensive Plan of Action (“JCPOA”) is appropriate and proportionate … Read More