Hena M. Schommer

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On 24 November 2013, the P5+1 countries (comprising the United States, Russia, China, the United Kingdom, France and Germany) together with Iran, agreed the Joint Plan of Action (JPOA), which relaxed some of the sanctions imposed against Iran by the EU and U.S. The JPOA was intended to provide interim sanctions relief, while the parties worked towards a more comprehensive and long-term solution. On 14 July 2015, the Joint Comprehensive Plan of Action (JCPOA) was agreed.…
In our alert of 8 July, we reported that the P5+1 and Iran had announced the extension of the Joint Plan of Action Relief Period (the JPOA Relief Period) to today, 10 July 2015. Negotiations with Iran continue. To allow more time for the parties involved to reach a long-term solution, the JPOA Relief Period has been further extended to Monday, 13 July 2015. As with the previous extension, the suspension and relaxation of…
On March 25, 2015, Schlumberger Oilfield Holdings, Ltd. (“SOHL”), a wholly owned subsidiary of Schlumberger Ltd., the world’s largest oil-field services company (collectively “Schlumberger”), agreed to plead guilty to criminal charges, enter into a plea agreement, and pay $232.7 million in penalties for willfully facilitating illegal transactions and engaging in trade with Iran and Sudan. The charges were brought under the International Emergency Economic Powers Act (“IEEPA”), 50 U.S.C. § 1705, which makes it…
This post was also written by Alexandra E. Allan and Tom C. Evans This alert follows our previous alerts on the Russia/Ukraine sanctions. U.S. Passes New Sanctions Authorizing Statute – Sends Russia Frigid End of Year Message President Obama: U.S. will “review and calibrate” sanctions in response to Russia’s actions On December 18, 2014, President Obama signed into law the Ukraine Freedom and Support Act of 2014 (“the Act”), the latest move in a series of sanctions…
This post was also written by Alexandra E. Allan, Laith Najjar, Tom C. Evans On 24 November 2013, an agreement was reached between the E3+3 (also known as the P5+1, and which includes the United States, United Kingdom, Russia, China, France and Germany) and Iran. This agreement, known as the Joint Plan of Action (JPOA), was the result of negotiations the aim of which was “to reach a mutually-agreed long-term comprehensive solution that would ensure Iran’s…
In January 2014, both the EU and U.S. brought into force measures which temporarily suspended and relaxed (for an initial period of six months) some of the sanctions in place against Iran. This reflected the Joint Plan of Action (JPOA) agreed to in November 2013 between Iran and the E3+3, also known as the P5+1, which includes, the U.S., Russia, China, the UK, France, and Germany. Those measures were discussed in our alerts of 24
As the United States and Russia continue to clash over Russia’s actions in the Ukraine, on September 12, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued additional sanctions further restricting designated Russian financial institutions’ access to capital markets, targeting Russian defense entities, and prohibiting exports to Russian entities that have been specifically designated as participants in exploration and production in deepwater, Arctic offshore, or shale projects. As part of these recent changes,…
On August 13, 2014, the Office of Foreign Assets Control (“OFAC”) revised its guidance on the status of entities owned by persons designated on the Specially Designated Nationals List (“SDN List”).  Under the new guidance, OFAC will consider an entity to be blocked if it is 50 percent or more owned, directly or indirectly, in the aggregate by one or more SDNs. This rule applies even if the entity is not itself listed on the…