Category Archives: Sanctions

Russia and Belarus Sanctions Update – March 17, 2022

Key Takeaways:

  • U.S., UK, and EU impose additional sanctions in response to Russia’s continued escalation of conflict in Ukraine
  • U.S. imposes sanctions on human rights violators and senior Russian defense officials
  • UK sanctions over 370 Russian individuals, including 51 oligarchs and their family members
  • EU imposes investment and trade restrictions and sanctions Russian oligarchs, propagandists, state-owned entities, and defense sector entities

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On March 15,… More

Russia and Belarus Sanctions Update – March 15, 2022

Key Takeaways:

  • New Executive Order prohibits certain imports and exports, and authorizes the Department of the Treasury to impose significant restrictions on U.S. investment in Russia
  • Additional wave of sanctions targeting Russian “elites” close to President Vladimir Putin
  • OFAC guidance clarifies that Russia-related sanctions prohibitions apply to cryptocurrency transactions

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On March 11, 2022, President Biden signed a new Russia-related Executive Order,… More

Russia and Belarus Sanctions Update – March 11, 2022

Key Takeaways:

  • The Biden administration announces ban on import of Russian energy commodities and prohibition on new investment in the Russian energy sector
  • New General License provides wind-down period until April 22, 2022 for certain energy imports from Russia pursuant to agreements entered into before March 8, 2022
  • EU and UK expand their sanctions programs against Russia and Belarus, including additional sanctions on oligarchs
  • FinCEN issued an alert to all financial institutions to be vigilant against efforts to evade the expansive sanctions and other restrictions imposed in connection with the invasion of Ukraine

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I.… More

Russia and Belarus Sanctions Update – March 7, 2022: U.S. Sanctions, Export Restrictions Escalate as Conflict in Ukraine Continues

Key Takeaways:

  • U.S. imposes additional sanctions on Russian elites, along with their family members, companies, and personal vehicles
  • Actions targeting the defense sector and Russian government-affiliated media outlets signal the expansion of U.S. sanctions to new industries
  • SWIFT access to be denied to seven Russian banks on March 12, 2022
  • New export controls target Belarus and further restrict export of items that use encryption to Russia and Belarus

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Russia Sanctions Update – February 28, 2022: U.S. Imposes Sanctions on Central Bank of Russia, Ministry of Finance, and Sovereign Wealth Funds; Switzerland and Monaco Impose Unprecedented Sanctions

Key Takeaways:

  • New Directive 4 prohibits transactions with Russian Central Bank, National Wealth Fund, and Ministry of Finance
  • Full blocking sanctions on Russian Direct Investment Fund and affiliates
  • Multi-lateral response to Russia’s invasion continues with unprecedented imposition of sanctions by Switzerland and Monaco

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On February 28, 2022, the U.S. government announced new sanctions on the Central Bank of Russia,… More

Review of Sanctions and Export Controls Imposed in Response to Russia’s Invasion of Ukraine

Key Takeaways:

  • The initial wave of sanctions targeted Russian banks and the financial industry plus individual “inner circle” elites, with more sanctions likely to follow in the coming weeks as events unfold.
  • Broad restrictions on debt and equity transactions with certain entities in the Russian financial, energy, and infrastructure sectors.
  • Expanded export controls, including foreign-direct product rule restrictions, new license requirements, and Entity List designations impact a wide range of exports to Russia.…
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European Union Approves Global Magnitsky-Style Human Rights Sanctions Regime

In a landmark development, the European Union’s Foreign Ministers on December 8 approved an “Action Plan on Human Rights and Democracy” that establishes a new mechanism for targeting systematic violators of human rights from any country in the world. The human rights community has colloquially termed the Action Plan “Europe’s Global Magnitsky Act”, an homage to the U.S. Global Magnitsky Human Rights Accountability Act that was passed by a wide bipartisan margin in Congress and signed into law by former President Obama at the end of his administration.… More

As the United States Targets China’s Human Rights Abuses, Companies Should Prepare for Stricter Due Diligence on Forced Labor

As the United States seeks to take more forceful action punishing China for its escalating human rights abuses against Muslim ethnic minorities in the Xinjiang autonomous region and the citizens of Hong Kong, international businesses whose supply chains intersect with China should be prepared for new legislation and regulatory enforcement that could result in penalties. Companies will need to take additional steps to ensure their due diligence processes account for potential human rights risks associated with forced labor in Xinjiang and elsewhere in the country.… More

Five on Friday – Five Recent Developments that We’ve Been Watching Closely

It’s Friday and time for another overview of developments in the field of business and human rights that we’ve been monitoring.

This week’s post includes: new guidance on compliance with North Korea-related sanctions laws; the release of the first annual report by the parties to the Dutch Banking Sector Agreement on International Responsible Business Conduct; and a new blog series on the “zero draft” of the proposed Treaty on Business and Human Rights.… More

Five on Friday – Five Recent Developments that We’ve Been Watching Closely

It’s Friday and time for another overview of developments in the field of business and human rights that we’ve been monitoring.

This week’s post includes: two new reports looking at corporate compliance with the U.K. Modern Slavery Act and best practices with respect to efforts to address the risks of forced labor; and the release of a “Frequently Asked Questions” document by the U.S. Department of Homeland Security regarding the presumption that goods made by North Korean workers are made with forced labor.… More

Trump Administration Announces Sanctions Pursuant to the Global Magnitsky Act

On December 21, 2017, the Trump Administration released a list of foreign nationals it has identified to be sanctioned in accordance with the Global Magnitsky Human Rights Accountability Act of 2016. In December 2016, we issued a client alert providing an overview of the legislation as it was being passed by Congress.   

Based on the Sergei Magnitsky Rule of Law Accountability Act of 2012 – which authorized imposition of sanctions on Russian nationals who grossly violate human rights or engage in massive corruption – the Global Magnitsky Act greatly expands the aperture of U.S.… More

Forced Labor and North Korean Workers: New Concerns for Importers

In Washington, D.C., the news this week focused on President Trump’s decision to designate (or redesignate) North Korea as a state sponsor of terrorism. For companies importing goods into the United States, developments this past August are likely to have more immediate impact.

On August 2, the United States enacted amendments to the North Korea Sanctions and Policy Enhancement Act of 2016. The amendments create a presumption that goods made by North Korean citizens or nationals,… More

Five on Friday – Five Recent Developments that We’ve Been Watching Closely

iStock_000011057325XSmallIt’s Friday and time for another overview of developments in the field of business and human rights that we’ve been monitoring.

This week’s post includes: the formal withdrawal of the United States from the EITI; the passage of the Canadian Magnitsky Act; and the launch of the Investor Alliance for Human Rights.

Five on Friday – Five Recent Developments that We’ve Been Watching Closely

iStock_000011057325XSmallIt’s Friday and time for another overview of developments in the field of business and human rights that we’ve been monitoring.

This week’s post includes: a paper from on the proposed draft elements for an international treaty on business and human rights; new guidance from the United Kingdom with regard to compliance with the Modern Slavery Act; and a review of corporate responsibility reporting.

  • On September 29,…
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Five on Friday – Five Recent Developments that We’ve Been Watching Closely

It’s Friday iStock_000011057325XSmalland time for another overview of developments in the field of business and human rights that we’ve been monitoring.

This week’s post includes: updates on litigation in the Doe v. Nestle case; a private members’ bill in the United Kingdom that would expand the scope of the Modern Slavery Act; and an easing of U.S. sanctions against Sudan.

  • As noted previously,…
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The Global Magnitsky Human Rights Accountability Act: A Sanctions Tool for Promoting the U.S. Human Rights Agenda

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This post, written by Isa Mirza and Gwendolyn Jaramillo, was originally published as a client alert by the firm’s Trade Sanctions & Export Controls and Corporate Social Responsibility practices. 

Overview

After months of closed-door discussions, Congress is near final passage of the negotiated National Defense Reauthorization Act (“NDAA”) for appropriating defense funds in fiscal year 2017. … More

Opportunity and Uncertainty for Entities Wishing to Do Business with Iran

globebookThe following is a client alert previously published here.  Questions should be directed to Gwendolyn Jaramillo or Shrutih Tewarie.

Nuclear Deal with Iran Holds Out Possibility of Phased Relaxation of Sanctions

On July 14, 2015, the United States and five other countries (collectively known as the P5+1) reached a Joint Comprehensive Plan of Action (JCPOA) with Iran under which Iran will limit its nuclear activities in exchange for a gradual lifting of international economic sanctions.… More

Alien Tort Case Development: The Second Circuit Assesses the Appropriate Focus of Jurisdictional Inquiries

Alien Tort GavelOn October 23, the Second Circuit Court of Appeals issued a decision in Mastafa v. Chevron Corp., a case filed against Chevron Corp. and BNP Paribas pursuant to the Alien Tort Statute (“ATS”). The court upheld the District Court’s dismissal of the plaintiffs’ complaint. In upholding the dismissal, the court held that the “focus” of the jurisdictional inquiry in ATS cases must be the specific conduct that allegedly violated the law of nations and where that conduct occurred.… More

The European Union Lifts Sanctions on Burma

iStock_000022174543XSmallOn April 22, the European Union lifted all sanctions on Burma except an arms embargo. The sanctions had already been eased in April 2012, which left open the option of easily putting them back into place. The European Union’s move to lift them altogether sends a strong signal of support for the reform-oriented government in Burma.

The European Union made this decision at a controversial time,… More

Looking Ahead: Five Developments We’ll be Watching in 2013

As memories of New Year’s Eve fade, and another Inauguration Day winds down in Washington, D.C., it’s time to look ahead and identify key events and emerging trends that we think will help shape the business and human rights agenda in 2013.

Here are five developments that we’ll be watching closely:

Further integration of human rights considerations into business management systems. Eighteen months after the release of the U.N.… More

Responsible Investment in Burma (Myanmar): An Experiment that Cannot Afford to Fail

Amy Lehr, the author of this post, will be presenting during a webinar on “Responsible Business in Myanmar: Operating Context, Sanctions, and International CSR Standards,” this Thursday, August 16, at 11:00 a.m. She will be joined by John Ruggie and Gare Smith. Information on registration can be found here.

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The U.S. decision to ease financial and investment sanctions on Burma for the first time since 1997 is a landmark – and controversial – moment.… More

Implications of Counterterrorism Measures for Companies Operating in Armed Conflict Situations

U.S. domestic counterterrorism measures are a critical component of the U.S. national security framework. Since the U.S. Supreme Court’s June 2010 decision in Holder v. Humanitarian Law Project, there has been renewed debate about the scope and impact of various U.S. measures including the Material Support Statute (18 U.S.C. § 2339B) and Executive Orders pursuant to the International Emergency Economic Powers Act (IEEPA) (50 U.S.C.… More

United States Eases Sanctions on New Investment in Burma (Myanmar)

On Thursday, May 17, 2012, President Obama announced that the U.S. would issue a general license easing sanctions on the export of financial services and new investment in Burma, although he did not lift them, meaning that they could be reinstated if there is backsliding on reforms. Although senior Administration officials had previously indicated that sanctions would only be eased on a few industries, the White House today announced that the general license would apply to all new investments in Burma,… More

New Executive Order Imposes Sanctions on Technology Companies that Facilitate Human Rights Abuses in Iran and Syria

The White House recently released a new Executive Order imposing sanctions on information technology companies that facilitate certain human rights abuses in Iran and Syria. Released on April 23, the Executive Order ("Blocking the Property and Suspending the Entry into the United States of Persons with Respect to Grave Human Rights Abuses by the Governments of Iran and Syria via Information Technology") explicitly applies to both individuals and entities. … More