Commerzbank will pay fines as part of a global settlement with a number of US authorities in relation to an investigation of alleged breaches of US sanctions regulations relating to Iran, Sudan, Burma and Cuba, Commerzbank will pay:  – US$258.7m to the US Treasury’s Department of the Office of Foreign Assets Control (OFAC) to settle […]

On Monday, 9 March 2015, President Obama signed an executive order http://1.usa.gov/1E6wwUE declaring a national emergency to deal with the threat to US national security and foreign policy posed by “the Government of Venezuela’s erosion of human rights guarantees, persecution of political opponents, curtailment of press freedoms, use of violence and human rights violations and abuses […]

Sanctions are prohibitive and restrictive measures directed at foreign governments and nations, individuals or groups, or non-state actors or groups. Sanctions have an impact on, among others, financial institutions and their customers through restrictions, and controls introduced on provision of goods and services and the movement of funds involving sanctioned countries, individuals and entities. Sanction […]

On February 14, 2008, OFAC issued guidance stating that the property and interests in property of an entity are blocked if the entity is owned, directly or indirectly, 50% or more by a person whose property and interests in property are blocked pursuant to an Executive Order or regulations administered by OFAC. Case study We […]

The US Treasury Department’s Office of Foreign Assets Control (“OFAC”) has imposed several new Ukraine-related sanctions as of July 16, 2014. Significantly, the new sanctions impose restrictions on certain types of dealings by US persons with specified Russian energy, defense and financial services entities.  The EU has also announced new sectoral sanctions, as well as […]

Mirroring the escalation of tensions in and around Ukraine, the EU, US, Canada and other countries have broadened economic sanctions targeting Russia and certain Russian and Ukrainian persons very significantly. In recent days the EU and each of the other countries adopted separate but coordinated packages of further sanctions. Taken together these measures, and particularly […]

On 31 July the EU Council agreed to impose the additional sanctions measures which are summarized below, and which will come into force on 1 August 2014 pursuant to an EU Regulation issued on 31 July: With a view to restricting Russia’s access to EU capital markets, EU nationals and companies may no longer buy […]

New Designations The US Office of Foreign Assets Control (“OFAC”) has issued several new sanctions designations in response to the developing situation in relation to Ukraine, and has also issued several significant clarifications regarding the scope of US Ukraine-related sanctions. OFAC has designated United Shipbuilding Corporation, a Russian state-owned enterprise, as a Specially Designated National. […]