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Sanctions, AML, Anti-Corruption Insights
Doing Business in Emerging Markets, Global Magnitsky Sanctions, Sanctions, United States China Law and Policy

U.S. Targets Chinese Belt & Road Project With Global Magnitsky Sanctions

The Treasury Department’s announcement of the sanctions speaks to the foreign policy and geostrategic significance of the UDG sanctions action. The release speaks of China’s “malign” investment in Cambodia, its use of the UDG projects in Cambodia to “advance ambitions to project power globally,” “disproportionality benefit” itself through BRI projects, and concerns that the Dara Kakor project “could be converted to “host military assets.” The Treasury Department’s language echoes U.S. concerns about the BRI and other Chinese international project financing activities, including that China engages in “debt trap” financing.
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International Emergency Economic Powers Act (IEEPA), Russia Sanctions, Sanctions

U.S. Sanctions on Nord Stream 2 and TurkStream Pipeline Projects (PEESA)

On December 20, 2019, the President signed into law the National Defense Authorization Act for Fiscal Year 2020 (NDAA), which authorizes the President to impose sanctions on foreign persons that knowingly sell, lease, or provide vessels for the construction of the Nord Stream 2 or TurkStream pipeline projects. The policies advanced by the NDAA are consistent with prior U.S. policy and legislation, particularly the Countering America’s Adversaries Through Sanctions Act. This MassPoint publication discusses PEESA’s policies, sanctions mechanics, the relationship between PEESA and CAATSA, and key takeaways.
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Doing Business in Emerging Markets, International Emergency Economic Powers Act (IEEPA), International Trade Law, Iran Sanctions, National Security Law, Sanctions, United States China Law and Policy

OFAC Cosco Shipping Tanker (Dalian) Co., Ltd. General License K: Analysis

General License K authorizes, until 12:01 eastern time on December 20, 2019 (essentially, through the end of December 19 eastern time), the above-listed prohibited transactions where they directly or indirectly involve Cosco or entities owned 50% by Cosco and are “ordinarily incident and necessary to the maintenance or wind down of transactions.”
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