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International Compliance Blog

OFAC Reactivates Sanctions against Belarussian Companies and Provides 45-day Wind Down Period

By Peter Jeydel, Ed Krauland & Brian Egan

April 20, 2021

On April 19, 2021, OFAC effectively reactivated longstanding sanctions against nine Belarussian companies and their subsidiaries, revoking a general license that had authorized transactions involving those entities since 2015. These sanctions may impact a significant number of Belarussian companies, as several of the listed entities are large conglomerates. US sanctions on Belarus were first imposed in 2006 under Executive Order 13405, with similar EU sanctions beginning in 2004, in response to concerns about the…

International Compliance Blog

New Russia Sanctions Focused on the Technology Sector and Sovereign Debt Markets

By Alexandra Baj, Peter Jeydel & Cherie Tremaine

April 19, 2021

On April 15, 2021, the White House and the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a package of economic sanctions targeting Russia, including expansive new legal authorities that would allow for the imposition of additional future sanctions on Russia in the technology sector and on Russian government bodies. OFAC has also issued expanded restrictions on participation in the primary market for Russian sovereign debt, and lending to the Russian…

International Compliance Blog

Treasury Removes UAE From Boycott List: Possible Implications

By Ed Krauland, Jack Hayes & Amanda Pedvin Varma

April 13, 2021

The Treasury Department has removed the United Arab Emirates (“UAE”) from its current list of countries which require or may require participation in, or cooperation with, an international boycott (within the meaning of section 999(b)(3) of the Internal Revenue Code). Iraq, Kuwait, Lebanon, Libya, Qatar, Saudi Arabia, Syria, and Yemen remain on the Treasury list. According to the Treasury Department, the UAE has been removed from the list due to the issuance of Federal Decree-Law…

International Compliance Blog

Entry Suspension on Temporary Work Visa Categories Ended

By Liz LaRocca & Dana Delott

April 5, 2021

The Presidential Proclamation prohibiting entry to the US by foreign nationals in key temporary, employment-based, immigration categories expired on March 31, 2021. As expected, the Biden administration permitted Presidential Proclamation 10052 to remain effective through to expiration, but did not extend the broad restrictions on certain H-1B (temporary professional), H-2B (temporary non-agricultural worker), J (exchange visitor) and L-1(intra-company transferee) foreign nationals. This reversal of a policy which began on June 22, 2020, is significant for…

International Compliance Blog

Client Alert: EU, UK, and US Adopt Myanmar Sanctions over Military Coup

By Alexandra Melia, Guy Soussan, Nicholas Turner, Evan Abrams, Stefan Tsakanakis & Charlotte Brett

March 29, 2021

In recent weeks, the EU, UK, and US have adopted sanctions against those allegedly involved in the military coup in Myanmar, along with those responsible for serious violations of human rights in overthrowing the democratically elected government or committing violence against protestors. The actions mark a sharp uptick in sanctions measures targeting Myanmar and suggest close coordination between the three jurisdictions. Additionally, on March 25, the UK and US took coordinated action, going beyond the…

International Compliance Blog

EU, UK, US and Canada Announce Coordinated Xinjiang Sanctions

By Alexandra Melia, Guy Soussan, Simon Hirsbrunner, Meredith Rathbone, Stefan Tsakanakis, Evan Abrams & Charlotte Brett

March 25, 2021

On March 22, 2021, the EU, UK, US and Canada announced a range of coordinated sanctions to crack down on alleged serious human rights abuses in the Xinjiang Uyghur Autonomous Region (XUAR). The coordinated announcements comprised measures of various types, including asset freezes and travel bans against individuals and entities alleged to be involved in serious human rights violations against Uyghurs and other minority groups in the XUAR. The measures elicited the swift imposition of…

International Compliance Blog

UK Government Acts on Commitment to Tackle Modern Slavery in Supply Chains with Centralised Modern Slavery Statement Registry

By Alexandra Melia

March 16, 2021

On March 11, 2021, the Home Office launched an online registry for organisations required to publish annual modern slavery statements under Section 54 of the Modern Slavery Act 2015 (“MSA”). The launch of the registry makes good on one of a series of commitments made by the UK government in October 2020 to strengthen the transparency in supply chains provision of the MSA, which we discussed in greater detail in a previous blog post (…

International Compliance Blog

OFAC FAQs Confirm the Suspension of the Restrictions on Xiaomi’s Securities Following District Court Injunction

By Wendy Wysong, Ed Krauland, Richard Battaglia & Nicholas Turner

March 15, 2021

Just three days before restrictions under Executive Order (EO) 13959 arising from Xiaomi Corporation’s designation by the US Department of Defense (DoD) as a Communist Chinese military company (CCMC) were to go into effect, on March 15, 2021, the US District Court for the District of Columbia granted Xiaomi’s request for a preliminary injunction order (the Court Order) against enforcement of the restrictions. Following the Court Order, on March 14, 2021, the US Treasury Department’s…

International Compliance Blog

Client Alert: OFSI Revises Guidance on Monetary Penalties for Breaches of UK Financial Sanctions

By Alexandra Melia

March 11, 2021

On March 10, 2021, the UK Office of Financial Sanctions Implementation (OFSI) published a revised version of its Monetary Penalties for Breaches of Financial Sanctions Guidance (Guidance), which will come into force on April 1, 2021. The new Guidance will be used to assess any potential financial sanctions breaches of which OFSI becomes aware on or after that date. The current version of the Guidance will remain applicable in the meantime. The structure and scope…

International Compliance Blog

Commerce Department Issues Significant New Export Controls in Response to Myanmar Coup

By Nicholas Turner, Ed Krauland, Meredith Rathbone, Wendy Wysong, Ali Burney & Peter Jeydel

March 11, 2021

On March 8, 2021, the US Commerce Department’s Bureau of Industry and Security (BIS) published amendments to the Export Administration Regulations (EAR) imposing new export control restrictions on Myanmar (Burma) and adding four entities to the Entity List, in response to a military coup in early February 2021. The BIS announcements follow the imposition of sanctions on 12 individuals and three entities by the US Treasury Department’s Office of Foreign Assets Control (OFAC), pursuant to…

International Compliance Blog

Blog Authors

OFAC Reactivates Sanctions against Belarussian Companies and Provides 45-day Wind Down Period

New Russia Sanctions Focused on the Technology Sector and Sovereign Debt Markets

Treasury Removes UAE From Boycott List: Possible Implications

Entry Suspension on Temporary Work Visa Categories Ended

Client Alert: EU, UK, and US Adopt Myanmar Sanctions over Military Coup

EU, UK, US and Canada Announce Coordinated Xinjiang Sanctions

UK Government Acts on Commitment to Tackle Modern Slavery in Supply Chains with Centralised Modern Slavery Statement Registry

OFAC FAQs Confirm the Suspension of the Restrictions on Xiaomi’s Securities Following District Court Injunction

Client Alert: OFSI Revises Guidance on Monetary Penalties for Breaches of UK Financial Sanctions

Commerce Department Issues Significant New Export Controls in Response to Myanmar Coup

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