President Trump signed a new Executive Order on August 6, 2018, titled “Reimposing Certain Sanctions with Respect to Iran”. The Executive Order was timed to coincide with the last day of the 90-day wind-down period established for activities associated with certain sanctions relief authorized by the Joint Comprehensive Plan of Action (“JCPOA”).  As a result, the first round of sanctions against Iran will become effective at 12:01 a.m. on August 7, 2018.
Continue Reading United States Announces Re-imposition of First Round of Nuclear Sanctions on Iran

CAATSA Overview

Congress enacted the “Countering America’s Adversaries Through Sanctions Act” (CAATSA) on August 2, 2017 in response to Russia’s continuing occupation of the Crimea region of Ukraine and cyber-interference in the 2018 United States Presidential elections. We previously covered CAATSA in blog posts here and here. CAATSA was notable because it passed the House of Representatives with a 419-3 approval margin and passed the Senate with a 98-2 approval margin. Among other things, CAATSA required President Donald Trump to take certain actions on the 180-day anniversary of CAATSA’s adoption, which included (but were not limited to): (i) imposing sanctions (commonly referred to as the “CAATSA Section 231 sanctions”) against persons engaged in “significant transactions” with Russia’s defense or intelligence sectors; and (ii) preparing and submitting a report (commonly referred to as the “CAATSA Section 241 report”) to various congressional committees identifying senior political figures and oligarchs within Russia. January 29, 2018 marked CAATSA’s 180-day anniversary and, as a result, it sparked a flurry of activity related to the CAATSA Section 231 sanctions and the CAATSA Section 241 report.
Continue Reading Russia Sanctions Developments Incite Controversy and Signal Possible Future Changes

White HouseToday, President Trump officially signed H.R. 3364, the “Countering America’s Adversaries Through Sanctions Act” (CAATSA) into law. CAATSA originated as a bill which was focused on only Iran. However, partially in response to Russian cyber-interference with the 2016 election, the Senate expanded CAATSA to impose additional sanctions against Russia and also codify into law various sanctions imposed by the Obama Administration in the form of Executive Orders. The House of Representatives then approved these additions and added further sanctions against North Korea. Eventually, the House and Senate approved the final version of CAATSA by a margin of 419-3 and 98-2, respectively. For additional detail on CAATSA’s legislative history, please see our previous alerts here, here and here.
Continue Reading President Signs Russian, Iran and North Korea Sanctions Legislation into Law

White HouseLast night, Thursday, July 27, the U.S. Senate voted to pass the “Countering America’s Adversaries Through Sanctions Act” by a vote of 98-2. The House of Representatives passed the bill on Tuesday after adding in new sanctions against North Korea. Among other things, the legislation would impose additional sanctions against Russia and restrict President Trump’s ability to withdraw or relax previous Russian sanctions imposed by the Obama Administration.  To learn more about the bill, please see our July 26th post. The Senate created the bill back in June, where it also passed 98-2, before sending it to the House. Despite reports that the addition of North Korea would result in a delay from the Senate, the Senate passed it just over 48 hours after the House.
Continue Reading Senate Sends Russian Sanctions Bill to the President

Congress ChamberYesterday, July 25th, the U.S. House of Representatives passed the “Countering America’s Adversaries Through Sanctions Act” by a vote of 419-3. The bill originated as an act in the Senate which was focused on Iran. In response to Russian meddling in the U.S. election, the Senate expanded that bill to include additional sanctions against Russia, codify various Russia-Ukraine sanctions promulgated by the Obama Administration into law and add procedural provisions to delay or prevent any efforts by the Trump Administration to relax those codified Obama Administration sanctions. The Senate passed their revised version of this legislation last month by a vote of 98-2. For more information on the Senate’s earlier approval, please see our post on June 16th.
Continue Reading Congress Passes Russian Sanctions Bill with New Sanctions on Russia, Iran and North Korea

globe AsiaOn Thursday, June 15, 2017, by a vote of 98-2, the U.S. Senate overwhelmingly passed a bill that would potentially impose additional sanctions against Russia and give Congress the power to delay and/or prevent any action by President Trump to lift or relax sanctions against Russia. Tentatively titled the “Countering Russian Influence in Europe and Eurasia Act of 2017” (“CRIEEA”), the bill must now proceed to the U.S. House of Representatives for further deliberation and approval.
Continue Reading Senate Passes Potential Russian Sanctions Bill

Shanghai ChinaOn Wednesday, Judge Richard Sullivan of the Southern District of New York relieved the Bank of China from an order issuing $50,000 of daily fines for failing to comply with two subpoenas for information on account holders accused of selling goods counterfeit “Gucci” goods. The matter provides an interesting case study of at least one dilemma facing foreign companies doing business in the United States – whether to comply with a US-issued subpoena knowing that compliance  would break foreign law.
Continue Reading Classic Catch 22? Dilemma of Foreign Companies Faced With Comply with US Subpoena and Possible Foreign Sanctions or Violate Subpoena and Possible Domestic Sanctions

On July 14, 2015, following nearly twenty months of talks, international negotiators from seven countries (the United States, the United Kingdom, China, France, Germany, Russia, and Iran) announced that they reached a landmark nuclear agreement to limit Iran’s nuclear program. While this is a historic agreement long in the making, it is important to note that there is no immediate lifting of sanctions against Iran. U.S. government officials have indicated that for now it is status quo for those focused on sanctions compliance.
Continue Reading Iran and World Powers Announce Landmark Nuclear Agreement

Yesterday, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced increased economic sanctions against Russia, including measures against Russia’s largest bank – Sberbank Russia – as well as several state-owned defense technology companies and five energy companies (Gazprom, Gazprom Neft, Lukoil, Surgutneftegas and Rosneft).  The United States has also tightened previous restrictions by lowering from 90 days to 30 days the allowable length of debt U.S. citizens and entities may buy from sanctioned Russian banks – Bank of Moscow, Gazprombank OAO, Vnesheconombank (VEB), Russian Agricultural Bank (Rosselkhozbank),  VTB Bank OAO and Sberbank Russia.
Continue Reading US and EU Tighten Sanctions against Russian Banks, Defense and Energy Sectors