Robert Slack

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U.S. Issues Enhanced Sanctions on Russian Energy Sector

As required under recent sanctions legislation, the U.S. Office of Foreign Assets Control (OFAC) recently issued an updated Directive 4 that will expand sectoral sanctions on the Russian energy industry. The new rules, which apply to projects initiated on or after January 29, 2018, will bar persons subject to U.S. jurisdiction from providing goods, services, or … Continue Reading

Secondary Sanctions Targeting Russia’s Defense and Intelligence Sectors Move Closer to Implementation

Last Friday the State Department belatedly released a list of 39 Russian entities that operate as part of Russia’s defense and intelligence sectors (the full list is below).  Congress required the Trump Administration to produce a list of such parties as part of the Countering America’s Adversaries Through Sanctions Act (CAATSA), which became law in … Continue Reading

OFAC Extends Sanctions Relief for Belarussian Conglomerates

Today the Office Foreign Assets Control (OFAC) extended sanctions relief for nine Belarussian conglomerates, including Belneftekhim. OFAC has authorized transactions with the listed Belarussian Specially Designated Nationals (SDNs) since October 2015 through a series of temporary general licenses. Today’s General License No. 2D extends the sanctions relief through April 30, 2018, subject to the restrictions … Continue Reading

The Paper Caper: U.S. Persons Cannot Help Foreign Subsidiaries or Affiliates with Sanctioned Country Transactions

A recent settlement agreement between the Office of Foreign Asset Control (OFAC) and BD White Birch Investment LLC, a U.S.-based paper company, is an important reminder that U.S. companies cannot assist their foreign subsidiaries or affiliates with sales related to sanctioned countries. … Continue Reading

EVENT ANNOUNCEMENT: What European Companies Need to Know About U.S. Sanctions, Export Controls, and FCPA Compliance

Join us in Brussels on November 9th, for this 2 hour seminar on what European companies need to know about U.S. sanctions, export controls, and anti-bribery compliance, co-hosted with the American Chamber of Commerce in Belgium.  We’ll tackle some of the most recent updates to U.S. sanctions rules, including the broad new sanctions on Russia mandated by … Continue Reading

Sale of Cartier Jewels Triggers OFAC Violations – Luxury Brands Should Be Aware of U.S. Sanctions Risks

A settlement agreement between Richemont North America, the parent company of Cartier, and the Office of Foreign Assets Control (OFAC) for violations of U.S. sanctions regulations is an important wake up call for U.S. and global retailers, which have often considered themselves to be somewhat outside the scope of U.S. sanctions laws.  In truth, the … Continue Reading

New U.S. Sanctions on North Korea – What You Need To Know

Last week the U.S. government announced new sanctions on North Korea designed to target non-U.S. persons, aircraft, vessels, and financial institutions that facilitate trade and transactions with the country.  The Executive Order contained four elements: new authority to designate persons as Specially Designated Nationals (SDNs), sanctions on certain aircraft and vessels that visit North Korea, … Continue Reading

U.S. Hits Venezuela and Petróleos de Venezuela (PdVSA) with Financial Sanctions

On Friday, August 25th, the U.S. government announced new financial sanctions on Venezuela.  The move is the most recent U.S. response to the escalating political and humanitarian crisis in the country.  The new Executive Order bars U.S. persons from: Dealing in ‘new debt’ of Petróleos de Venezuela (PdVSA), Venezuela’s state-owned oil company, that has a … Continue Reading

U.S. Targets Chinese and Russians for North Korea Dealings

The Office of Foreign Assets Control (OFAC) designated 16 parties as Specially Designated Nationals (SDNs) today, effectively seizing their assets in the United States, blocking them from doing business with U.S. parties, and denying them access to the U.S. financial system.  The designations mark the latest escalation of sanctions on North Korea and an increasing … Continue Reading

New Russia, Iran, and North Korea Sanctions Become Law

Today the President signed landmark legislation into law mandating new and enhanced sanctions on Russia, Iran, and North Korea.  As noted in our prior posts, here and here, the law will tighten existing sanctions on those countries and provide the U.S. government with broader power to penalize companies under primary and secondary sanctions rules. Please … Continue Reading

U.S. Blacklists the President of Venezuela as a Specially Designated National (SDN)

Today the U.S. Office of Foreign Assets Control (OFAC) took the unusual step of blacklisting the leader of a foreign country as a Specially Designated National (SDN).  OFAC added Nicolas Maduro, the President of Venezuela, to the SDN List after a flawed vote that essentially replaced the country’s democratically elected legislature with a new body … Continue Reading

Congress Passes Landmark Russia Sanctions

Last night the U.S. Senate passed sweeping sanctions on Russia, Iran, and North Korea by a vote of 98-2.  The Countering America’s Adversaries Through Sanctions Act (the Act) contains important changes to U.S. sectoral sanctions on Russia and provides enhanced authority to issue primary and secondary sanctions on that country. The bill looks likely to … Continue Reading

President Punts on Sudan Sanctions

The President issued a new Executive Order today delaying a decision on whether to permanently lift sanctions on Sudan. In January, President Obama announced the interim lifting of U.S. sanctions on Sudan.  At that time the Office of Foreign Assets Control (OFAC), the agency primarily responsible for implementing U.S. sanctions, issued a general license (or … Continue Reading

US Govt Seeks $1.9 Million In North Korea Sanctions and Money Laundering Case

A recent suit filed by the U.S. Department of Justice (DOJ) for the forfeiture of nearly $2 million highlights the broad extraterritorial reach of U.S. sanctions laws.  On June 14, DOJ filed a complaint to seize funds associated with transactions between several Chinese companies, including Mingzheng International Trading Limited (Mingzheng).  Mingzheng and the other companies … Continue Reading

Congress Takes The Lead In Broad New Sanctions Against Russia

On June 15, 2017, the Senate overwhelmingly – by a vote of 98-2 – approved broad new sanctions against Russia in response to that country’s interference in the 2016 U.S. election and its ongoing aggression in Syria and Ukraine. The legislation would make several big changes.  First, the package would codify existing sanctions on Russia, … Continue Reading
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