The latest on Russia sanctions from the International Trade and Supply Chain Team
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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

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

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

Continue Reading The Government Continues to Prioritize Export Control and Sanctions Enforcement Highlighted in New Tri-Seal Compliance Note and Cooperative Agreement Between BIS and OFAC. 

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.

Continue Reading President Trump Imposes Sanctions Against Turkey for its Syria Offensive

On April 21, 2019, the White House announced that President Trump has decided not to reissue the Iranian oil sanctions waivers, called “Significant Reduction Exceptions” (SREs) when they expire in early May. The White House statement explained that “[t]his decision is intended to bring Iran’s oil exports to zero, denying the regime its principal source of revenue.”
Continue Reading President Trump to End Sanctions Waivers for Iranian Oil