Executive Order

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On June 11, 2020, the President issued an Executive Order (the “Order”), “Blocking Property of Certain Persons Associated with the International Criminal Court,” which authorizes the Secretary of State to impose blocking sanctions on certain persons involved in investigations by the International Criminal Court (“ICC”) of U.S. and allied military…
Continue Reading President Trump Takes Aim at the International Criminal Court with New Sanctions Order

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 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

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 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

The past two weeks have seen a number of developments with respect to U.S. sanctions relating to Russia, as the Trump administration has (1) taken additional steps to ameliorate adverse consequences for U.S. persons of the significant sanctions actions targeting Russian oligarchs announced on April 6, 2018; (2) further implemented…
Continue Reading Russia Sanctions Updates

On August 6, 2018, President Trump issued Executive Order (“E.O.“) 13846,  further implementing his May 8, 2018 decision to terminate the United States’ participation in the Joint Comprehensive Plan of Action with Iran (“JCPOA”). The following day, as certain re-imposed sanctions took effect, the President…
Continue Reading President Trump Issues Executive Order Re-Imposing Iran Sanctions, Signals Aggressive Enforcement to Come

There are distinct, but subtle, shifts in tone in the FSOC’s 2017 Annual Report, especially when compared to previous annual reports and read together with three recent Treasury reports on financial regulatory reform, each of which touches on the role of the FSOC.[1] Taken as a whole, the 2017…
Continue Reading FSOC 2017 Annual Report—A Subtle Shift in Tone that Signals the Possibility of Meaningful Change

The U.S. Treasury’s new Capital Markets Report recommends additional administrative requirements for regulatory actions by the SEC and the CFTC (the “Agencies”).  If adopted, the process by which the Agencies issue new regulations and guidance may be more transparent and subjected to more rigorous cost-benefit analysis.  Rulemaking and issuing no-action…
Continue Reading Treasury Report Recommends Additional Process and Constraints for Market Regulators