Economic Sanctions

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On April 24, 2024, President Biden signed into law the 21st Century Peace through Strength Act, Pub. L. No. 118-50, div. D. Part of the Act included a provision extending the statute of limitations for civil and criminal violations of the International Emergency Economic Powers Act (IEEPA) and the Trading with the Enemy Act (TWEA) from five years to 10 years. The new statute of limitations took effect on the date of the President’s signature.

Omaha-based partner Grant Leach appeared last week on an episode of The Justice Insiders podcast to discuss the ever-expanding set of requirements and restrictions placed on U.S. businesses in connection with trade law, including a key change in the statute of limitations—from five years to ten—in connection with the Office of Foreign Assets Control (OFAC)…

Executive Order Imposes New Russia Sanctions for Foreign Financial Institutions and Prohibits Additional Russian Imports

On December 22, 2023, President Biden issued Executive Order 14114, which amended previous Executive Orders in order to authorize the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) to impose additional Russia-related sanctions on foreign financial institutions and…

On July 27, 2023, the Department of Commerce’s Bureau of Industry and Security (BIS) announced that U.S. persons reporting boycott-related requests to its Office of Antiboycott Compliance (OAC) must now also disclose the identity of the specific party that made the request.  Previously, U.S. persons were required to disclose when they had received a boycott-related…

On Wednesday, July 26, the Departments of Commerce, Treasury, and Justice issued a Tri Seal Compliance Note detailing the voluntary self-disclosure of potential violations for export controls, sanctions, and other national security laws. The Compliance Note highlights the new changes made to the Department of Justice’s voluntary self-disclosure policy. The Note also provided an overview…

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Check out the latest episode of The Justice Insiders—a podcast hosted by Husch Blackwell partner Gregg Sofer—where we explore the intersection of international trade law and government investigations and enforcement, particularly in connection with Russia.

I previously appeared on Gregg’s podcast during the first quarter of 2022, and we pick up that…

We are pleased to announce that our team’s fourth-annual international trade law year-in-review report was published just before the New Year. In it, we take a detailed look at how 2022 played out and explore how 2023 might develop. As companies continue to work through the challenges associated with supply chain dislocations, geopolitical turmoil, and…

Herbert Hoover Building Commerce Department 14th Street Washingt
Main Entrance Herbert Hoover Building Commerce Department 14th Street Washington DC. Building completed in 1932. Across from the White House, Commerce has multiple departments.

BIS Adds 24 New Entities and Removes One from Entity List

On December 8, 2022, the Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a notice in the Federal Register adding 24 entities under 26 entries and removing one entity from the Entity List. The entities are from Latvia, Pakistan, Russia, Singapore, Switzerland…

Russia has amassed more than 100,000 troops at the Ukrainian border, leading the White House to issue a warning on January 25 that the U.S. is “prepared to implement sanctions with massive consequences that were not considered in 2014 [when Russia invaded and annexed the Crimea region of Ukraine]” if Russia “further invades Ukraine”.  President…

On October 14, 2019, President Trump announced via Twitter his intention to authorize sanctions against Turkey and “any persons contributing to Turkey’s destabilizing actions in northeast Syria.” The announcement followed Turkey’s recent military operation against predominately Kurdish forces in northern Syria, which began following the withdrawal of U.S. troops from the region. Later in the day, President Trump issued an Executive Order (the “Syria-Turkey EO”) to formally implement those sanctions. Under the Syria-Turkey EO:

  • The U.S. Secretary of the Treasury is now authorized to impose blocking sanctions on any person that it determines to be: (i) responsible for or complicit in actions that threaten Syrian stability or abuse human rights, (ii) an official or agency of the Government of Turkey, or (iii) operating in sectors of the Turkish economy that the Secretary of Treasury might later decide to target with sanctions. The Syria-Turkey EO also authorizes the Treasury Secretary to impose blocking sanctions on any person (including non-U.S. persons) who provides material assistance, goods or services to or in support of any person sanctioned under the Syria-Turkey EO.
  • The U.S. Secretary of the Treasury is authorized to restrict or prohibit foreign financial institutions from opening or maintaining correspondent or payable through accounts in the U.S. if the Treasury Department determines that those foreign financial institutions have knowingly conducted or facilitated any significant financial transaction for or on behalf of any person who becomes subject to the above-described blocking sanctions.
  • The U.S. Secretary of State is now authorized to impose menu-based sanctions on any person the Secretary determines to have interfered with peacekeeping and restorative efforts in northern Syria. These authorized menu-based sanctions include (but are not limited to): blocking sanctions, denial of U.S. entry visas and financing-based sanctions.