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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Economic Sanctions
U.S. Government Targets “Three Stooges of Socialism” with New Measures Against Cuba, Venezuela, and Nicaragua
Posted in Economic Sanctions, OFAC
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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U.S. Government Adds to Sanctions Against the IRGC with Unprecedented FTO Designation
Posted in Economic Sanctions, OFAC
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…
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In Unprecedented but Mostly Symbolic Move, State Department Allows Some Claims under Title III of the Libertad Act
Posted in Economic Sanctions, OFAC
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…
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Davis Polk Financial Services Regulatory Reform Tool—New Congress Edition
Financial services regulatory reform continues to evolve in 2019. As we observe the changing landscape, here is the New Congress Edition of our reference tool, which provides context and summarizes current developments across a range of key regulatory areas, agencies and actors. We will continue to track these issues and…
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OFAC Designates PdVSA
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…
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OFAC Announces Intent to Delist Rusal and Other Entities Owned by Sanctioned Oligarch Deripaska
Posted in Economic Sanctions, OFAC
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…
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First Step Toward Defining “Emerging Technology” Under Export Control Reform Act
On November 19, 2018, the Commerce Department’s Bureau of Industry and Security (“BIS”) issued an advance notice of proposed rulemaking (“ANPRM”) seeking public comment on “criteria for identifying emerging technologies that are essential to U.S. national security.”[1] The ANPRM was issued pursuant to the Export Control Reform…
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U.S. Prosecutors and Regulators Impose Second Largest Penalty Ever Levied Against a Financial Institution for Violations of U.S. Economic Sanctions
On November 19, 2018, a group of five U.S. federal and state prosecutors and regulators[1] announced that they had reached settlements with Société Générale (“SocGen”) under which SocGen will pay penalties totaling $1.34 billion in relation to violations of U.S. economic sanctions concerning Iran, Cuba, Sudan and…
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Davis Polk Financial Services Regulatory Reform Tool—Post Midterm Election Edition
Posted in Administrative Law, Anti-Money Laundering, Bank Capital, Bank Regulation, CFPB, CFTC, Community Reinvestment Act, Cost-Benefit Analysis, Dodd-Frank, Economic Sanctions, FDIC, Federal Reserve, Fintech, FSOC, Legislation, Liquidity, OCC, OFAC, Stress Testing, Swap Regulation, TLAC, U.S. Basel III, U.S. Congress, Volcker Rule
Financial services regulatory reform will continue to evolve in 2018 and 2019. As we observe the changing legislative landscape, here is the Post Midterm Election Edition of our reference tool, which provides context and summarizes current developments across a range of key regulatory areas, agencies and actors. We will continue…
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