President Trump signed a new Executive Order on August 6, 2018, titled “Reimposing Certain Sanctions with Respect to Iran”. The Executive Order was timed to coincide with the last day of the 90-day wind-down period established for activities associated with certain sanctions relief authorized by the Joint Comprehensive Plan of Action (“JCPOA”).  As a result, the first round of sanctions against Iran will become effective at 12:01 a.m. on August 7, 2018.
Continue Reading United States Announces Re-imposition of First Round of Nuclear Sanctions on Iran

CAATSA Overview

Congress enacted the “Countering America’s Adversaries Through Sanctions Act” (CAATSA) on August 2, 2017 in response to Russia’s continuing occupation of the Crimea region of Ukraine and cyber-interference in the 2018 United States Presidential elections. We previously covered CAATSA in blog posts here and here. CAATSA was notable because it passed the House of Representatives with a 419-3 approval margin and passed the Senate with a 98-2 approval margin. Among other things, CAATSA required President Donald Trump to take certain actions on the 180-day anniversary of CAATSA’s adoption, which included (but were not limited to): (i) imposing sanctions (commonly referred to as the “CAATSA Section 231 sanctions”) against persons engaged in “significant transactions” with Russia’s defense or intelligence sectors; and (ii) preparing and submitting a report (commonly referred to as the “CAATSA Section 241 report”) to various congressional committees identifying senior political figures and oligarchs within Russia. January 29, 2018 marked CAATSA’s 180-day anniversary and, as a result, it sparked a flurry of activity related to the CAATSA Section 231 sanctions and the CAATSA Section 241 report.
Continue Reading Russia Sanctions Developments Incite Controversy and Signal Possible Future Changes

White HouseToday, President Trump officially signed H.R. 3364, the “Countering America’s Adversaries Through Sanctions Act” (CAATSA) into law. CAATSA originated as a bill which was focused on only Iran. However, partially in response to Russian cyber-interference with the 2016 election, the Senate expanded CAATSA to impose additional sanctions against Russia and also codify into law various sanctions imposed by the Obama Administration in the form of Executive Orders. The House of Representatives then approved these additions and added further sanctions against North Korea. Eventually, the House and Senate approved the final version of CAATSA by a margin of 419-3 and 98-2, respectively. For additional detail on CAATSA’s legislative history, please see our previous alerts here, here and here.

Continue Reading President Signs Russian, Iran and North Korea Sanctions Legislation into Law

North America MapAfter more than a half-century, the U.S. has finally taken steps toward normalizing its relations with Cuba. In a series of executive actions on December 17, 2014, President Obama announced changes to existing regulations that will ease sanctions against Cuba.

U.S. and Cuban officials will meet on February 27, 2015 at the State Department to continue talks of restoring ties and ending the embargo. Likely sticking points will be the opening of a U.S. Embassy in Havana, Cuba’s continuing appearance on the U.S. list of countries that support and sponsor terrorism, the potential return of Guantanamo Bay to Cuba, and U.S. support for Cuban political dissidents.

The executive actions alone however offer various opportunities for U.S. and Cuban businesses. This is particularly true in industries such as telecommunications and agriculture where technological and scientific advances could lead to improved infrastructure and increased production.


Continue Reading U.S.-Cuba Relations

Yesterday, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced increased economic sanctions against Russia, including measures against Russia’s largest bank – Sberbank Russia – as well as several state-owned defense technology companies and five energy companies (Gazprom, Gazprom Neft, Lukoil, Surgutneftegas and Rosneft).  The United States has also tightened previous restrictions by lowering from 90 days to 30 days the allowable length of debt U.S. citizens and entities may buy from sanctioned Russian banks – Bank of Moscow, Gazprombank OAO, Vnesheconombank (VEB), Russian Agricultural Bank (Rosselkhozbank),  VTB Bank OAO and Sberbank Russia.
Continue Reading US and EU Tighten Sanctions against Russian Banks, Defense and Energy Sectors