BIS advises financial institutions to guard against EAR violations through: (1) screening against export lists, (2) enhanced due diligence for high-risk transactions, (3) derisking, and (4) reporting and self-disclosing EAR violations. The BIS guidance reiterates FIs’ obligation to file suspicious activity reports (SARs) as directed in three prior FinCEN-BIS alerts.
OFAC – Swedbank Latvia Settlement Settlement Highlights Importance of Integrating Geolocation and Know Your Customer Data By Hdeel Abdelhady | June 23, 2023…
Hdeel Abdelhady to speak on sanctions, Georgetown Law National Security & Policy Event Hdeel Abdelhady will speak at the Georgetown Law School Journal…
In this Reuters commentary, Hdeel Abdelhady discussed U.S. blocking and non-blocking Ukraine-related sanctions on Russia, and their likely impacts.
Russia Sanctions in Response to Ukraine Invasion, by Hdeel Abdelhady February 28, 2022 ▪ Author: Hdeel Abdelhady ▪ Topics: Russia Sanctions, Sanctions In…
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.
The Haverly case is instructive as it clarifies OFAC’s position, with respect to Haverly and likely more broadly, as to the meaning of “debt” under Directive 2, which prohibits, by U.S. persons and within the United States, dealings in “new debt” issued by parties that are listed on the OFAC-maintained Sectoral Sanctions Identifications List (SSIL) or not so listed but are owned 50% or more by one or more sanctioned parties.
As required by the Countering Russian Influence in Europe and Eurasia Act of 2017 (CRIEEA), the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) on September 29, 2017 amended and reissued OFAC Directive 1 (Directive 1). As amended, Directive 1 continues to prohibit certain “new” debt, equity, and related transactions involving entities subject to U.S. Sectoral Sanctions targeting Russia’s financial services sector. This Business Update discusses the background to and mechanics of Directive 1 as amended and reissued.
OFAC Directive 1 Explainer: “New” Financing, Debt, Equity In light of the July 30, 2015 addition to the U.S. Sectoral Sanctions list of…