Sanctions Notes

New year, new UK sanctions regime

Upon the end of the Brexit transition period at 11pm on 31 December 2020, the UK ceased to implement EU sanctions. UK sanctions are now in force under …

The US Government Rescinds Sudan’s State Sponsor of Terrorism Designation

OFAC Introduces Non-SDN Menu-Based Sanctions List

On December 14, OFAC published a new “Non-SDN Menu Based Sanctions List.” The publication is designed to be a reference tool that identifies individuals …

New Guidance Document Clarifies Due Diligence Expectations for Charities and Non-Profit Bank Customers

On November 19, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Financial Crimes Enforcement …

EU introduces global human rights sanctions regime

US Federal Agencies Continue the US “Maximum Pressure” Campaign

In series of coordinated actions and announcements during the course of October and November 2020 (the Recent Iran Actions), three US federal …

OFAC Extends Venezuela General License 8, Enabling US Energy Companies to Continue Engaging in Limited Activities With PdVSA

OFAC Issues Advisory Highlighting Sanctions Risks Arising from Transactions Involving High-Value Artwork

On October 30, OFAC published an advisory (the “Advisory”), which highlights sanctions risks arising from transactions involving high-value artwork …

US Department of State Issues Guidance on Human Rights Due Diligence for Surveillance-Capable Products and Services

On September 30, 2020, the US Department of State published new guidance on human rights due diligence for US businesses involved in the sale of products …

OFSI Releases its Third Annual Review for 2019-2020

Update on Section 889 Restrictions Relating to Telecommunications and Video Surveillance Services or Equipment from Certain Chinese Companies

OFAC Issues New Venezuela General License, Effectively Delaying Creditors’ Ability to Seize Citgo Assets