Sanctions

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In this session, hosts and International Trade Practice Leaders Nicole Simonian and Dj Wolff talk with Crowell lawyers Jeremy Iloulian and Laurel Saito about the significant new sanctions and export control authorities included in the recently enacted National Security Supplemental fiscal package. While this legislation is best known for providing U.S. foreign aid commitments for…

The latest U.S. foreign aid bill supporting Ukraine, Israel, and Taiwan enacted on April 24, 2024 enhances U.S. sanctions and export controls including expanding (1) the statute of limitations for sanctions violations; (2) the President’s authority to coordinate sanctions efforts with the European Union and the United Kingdom; (3) sanctions and export controls on Iran…

On Thursday, April 18, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced new sanctions on Iran following its April 13, 2024 attack on Israel. OFAC designated 16 individuals and ten entities as Specially Designated Nationals and Blocked Persons (SDN), specifically those involved in Iran’s unmanned aerial vehicle (UAV), steel, and…

On March 6, 2024, the Department of Commerce, the Department of the Treasury, and the Department of Justice published a Tri-Seal Compliance Note titled “Obligations of foreign-based persons to comply with U.S. sanctions and export control laws” (the “Note”). The Note stresses that U.S. persons are not the only entities subject to U.S. sanctions and…

On January 17, 2024, the US Department of the Treasury (“Treasury”) Office of Foreign Assets Control (“OFAC”) announced the re-addition of Ansarallah, better known as the Houthis, to the List of Specially Designated Nationals and Blocked Persons (“SDN List”) as a Specially Designated Global Terrorist, just shy of three years after delisting the group to…

Last week, OFAC announced it is increasing its maximum amount of the civil monetary penalties (CMP) that may be assessed under relevant OFAC regulations by implementing the Federal Civil Penalties Inflation Adjustment Act of 1990 for 2024. These increases adjust for inflation and have occurred nine times since 2015. The changes to the CMPs are…

On December 11, the U.S. Department of Treasury (“Treasury”)’s Office of Foreign Assets Control (“OFAC”) announced sanctions against two former Afghan government officials, Mir Rahman Rahmani and his son, Ajmal Rahmani (collectively, “the Rahmanis”), as well as 44 associated entities. These individuals and entities were designated pursuant to Executive Order 13818, which builds upon and…

  • In a move that could lead to the quasi-harmonization between Member States of certain aspects of criminal law, the EU institutions are currently considering a new law that would criminalize sanctions evasion.
  • Following the creation of the European Public Prosecutor’s Office (EPPO) in 2021, members of the European Parliament are now seeking the
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Last Friday, the U.S. Departments of Commerce, Justice, State, and the Treasury issued a joint guidance sheet on Iran’s unmanned aerial vehicles (“UAVs”) program (the “Iran UAV Guidance”). The Iran UAV Guidance highlighted (I) the threat Iran’s UAV program poses; (II) the key items that Iran relies on to expand its UAV program; (III) the…

New U.S., UK, and EU Designations: On September 30, 2022, the U.S. designated 295 individuals and entities.  The new designations included 14 persons in Russia’s military industrial complex, including Sinno Electronics Co. and Taco LLC, Chinese and Armenian suppliers, for their support of a Russian defense procurement firm.  The U.S. also targeted two Russian…