Alexander Brandt

Firm/Organization: Reed Smith LLP

Blogs: Global Regulatory Enforcement Law Blog, Ship Law Log

Latest Articles

U.S. updates guidance for the shipping industry on tactics used to illegally procure Iranian oil for Syria

By Leigh T. Hansson, Alexander Brandt, Eli Rymland-Kelly, William Young & Gautam Lamba on April 1, 2019

On Monday, March 25, 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) updated the advisory document it published in November 2018 on the risks for parties involved in petroleum shipments to Syria. The update adds to the list of deceptive shipping practices used to obfuscate the destination of petroleum bound for Syria and the measures that members of the petroleum shipping community can take to mitigate these risks. This guidance…

Global Regulatory Enforcement Law Blog

OFAC addresses North Korea’s illicit shipping practices with updated advisory document

By Leigh T. Hansson, Alexander Brandt, Eli Rymland-Kelly & Bianca Casini on March 26, 2019

On Thursday March 21, 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) updated the advisory document it published on February 23 regarding North Korea’s illicit shipping practices. The updated guidance provides further information about North Korea’s deceptive shipping practices aimed at evading international sanctions and provides a list of ‘red flags’ aimed at assisting in the identification of these deceptive practices. This guidance follows North Korea’s continued attempts to evade…

Global Regulatory Enforcement Law Blog

OFAC imposes strong sanctions on Venezuela’s PDVSA

By Alexander Brandt, Leigh T. Hansson, Chloe Rogers & Eli Rymland-Kelly on January 31, 2019

On Monday January 28, the U.S. Department of Treasury, Office of Foreign Assets Control (OFAC) imposed strong sanctions on Petróleos de Venezuela, S.A. (PdVSA), a major Venezuelan state-owned oil and natural gas company. The U.S. is now prohibited from engaging in transactions with the company, and all property and interests in property of PdVSA that are subject to U.S. jurisdiction are blocked. Members of our Sanctions Team describe the impacts of this action in our client …

Global Regulatory Enforcement Law Blog

United States fully reimposes secondary sanctions on Iran

By Leigh T. Hansson, Chloe Rogers, Jeffrey Orenstein, Alexander Brandt & Eli Rymland-Kelly on November 13, 2018

On November 5, the United States reimposed the final tranche of sanctions on Iran, which had been lifted pursuant to the Joint Comprehensive Plan of Action (“JCPOA”) in 2016. The vast majority of these sanctions are “secondary sanctions,” being those which target non-U.S. persons and companies even where there is no U.S. nexus (e.g. the use of USD; U.S.-persons; or U.S. goods). The secondary sanctions cover a variety of goods and services, as well as…

Global Regulatory Enforcement Law Blog

Iran Sanctions: new developments and how to handle them

By Leigh T. Hansson, Chloe Rogers, Alexander Brandt & Eli Rymland-Kelly on October 30, 2018

On 8 May 2018, President Trump announced that the United States would withdraw from the Joint Comprehensive Plan of Action (JCPOA). In conjunction with that announcement, the President issued a National Security Presidential Memorandum (NSPM) directing the re-imposition of certain secondary sanctions, being those that apply to non-U.S. persons even where there is no U.S. nexus (e.g. no U.S. persons, no U.S.-origin goods, or U.S. dollar payments). As discussed in our earlier blog post,…

Ship Law Log

IRAN SANCTIONS – UPDATE

By Leigh T. Hansson, Chloe Rogers, Alexander Brandt & Eli Rymland-Kelly on October 30, 2018

Ship Law Log

The English High Court provides much needed guidance on the effectiveness of sanction exclusion language, following the USA’s withdrawal from the JCPOA

By Chloe Rogers & Alexander Brandt on October 25, 2018

After a tumultuous year in the Iranian sanctions landscape, much needed guidance is starting to trickle down through the English courts as to the scope and application of the US secondary sanctions and the EU Blocking Regulation regimes. On 12 October 2018, the English High Court handed down judgment in Mamancochet Mining Ltd v Aegis Managing Agency Ltd [2018] EWHC 2643 (Comm), in which Teare J was asked to consider contractual sanctions exclusion clause wording…

Ship Law Log

Sanctions on Iran – Fight for the survival of the JCPOA

By Leigh T. Hansson, Chloe Rogers, Alexander Brandt & Eli Rymland-Kelly on September 27, 2018

As readers will be aware, following President Trump’s announcement on 8 May 2018, the USA has indicated its withdrawal from the Iran nuclear deal – the JCPOA – and that it will be reimposing secondary sanctions on Iran, being those which affect non-U.S. persons. The first tranche of secondary sanctions took effect in early August, with the second to follow in early November. The remaining participants to the JCPOA, including the EU, have been looking…

Ship Law Log

IRAN SANCTIONS: UNITED STATES REIMPOSES SANCTIONS AND THE EU RESPONDS

By Leigh T. Hansson, Chloe Rogers, Alexander Brandt & Eli Rymland-Kelly on August 7, 2018

In the early hours of Tuesday, 7 August 2018, and as foreshadowed by President Trump’s announcement on 8 May 2018, the United States reimposed certain secondary sanctions on Iran, being those which apply to non-U.S. persons. The imposition of these sanctions follows the conclusion of a 90-day wind-down period and, as mentioned in our previous blog post, will impact (among other things) trade in graphite, raw or semi-finished metals and the Iranian automotive sector.…

Global Regulatory Enforcement Law Blog

Iran sanctions: United States reimposes sanctions and the EU responds

By Leigh T. Hansson, Chloe Rogers, Eli Rymland-Kelly & Alexander Brandt on August 7, 2018

Alexander Brandt

U.S. updates guidance for the shipping industry on tactics used to illegally procure Iranian oil for Syria

OFAC addresses North Korea’s illicit shipping practices with updated advisory document

OFAC imposes strong sanctions on Venezuela’s PDVSA

United States fully reimposes secondary sanctions on Iran

Iran Sanctions: new developments and how to handle them

IRAN SANCTIONS – UPDATE

The English High Court provides much needed guidance on the effectiveness of sanction exclusion language, following the USA’s withdrawal from the JCPOA

Sanctions on Iran – Fight for the survival of the JCPOA

IRAN SANCTIONS: UNITED STATES REIMPOSES SANCTIONS AND THE EU RESPONDS

Iran sanctions: United States reimposes sanctions and the EU responds

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