Sanctions Expert’s Post

OFAC adds “secondary sanctions risk” to Russia listings OFAC has added the language "Secondary sanctions risk: See Section 11 of Executive Order 14024” to thousands of Russia sanctions listings. Foreign financial institutions risk being designated for facilitating transactions involving any DP subject to EO 14024 – see updated OFAC advisory for foreign financial institutions and FAQs 1146-1157. https://lnkd.in/eJzMeMcg #UKSanctions #Russia #EUCommission #ExportControl #TradeWar #TSECS #SanctionsUpdate #TurkishSociety #Sanctions #USA #OFAC #BIS #TradeUpdates #GlobalTrade #TradeCompliance #InternationalRelations #EconomicSanctions #TradeRegulations #TurkishExports #TradePolicy #SecurityMatters #ForeignPolicy #ComplianceNews #EconomicSecurity #CrossBorderBusiness

OFAC adds “secondary sanctions risk” to Russia listings OFAC has added the language "Secondary sanctions risk: See Section 11 of Executive Order 14024” to thousands of Russia sanctions listings. Foreign financial institutions risk being designated for facilitating transactions involving any DP subject to EO 14024 – see updated OFAC advisory for foreign financial institutions and FAQs 1146-1157. https://lnkd.in/d9CUTVS2 #UKSanctions #Russia #EUCommission #ExportControl #TradeWar #TSECS #SanctionsUpdate #TurkishSociety #Sanctions #USA #OFAC #BIS #TradeUpdates #GlobalTrade #TradeCompliance #InternationalRelations #EconomicSanctions #TradeRegulations #TurkishExports #TradePolicy #SecurityMatters #ForeignPolicy #ComplianceNews #EconomicSecurity #CrossBorderBusiness

July 23rd has come and gone, a day that imposed numerous deadlines for sanctions-related tasks under the April 24, 2024 National Security Package on the President (i.e., OFAC). Several reports in relation to Russia, Iran (e.g. the "MAHSA Act"), and terrorism were required to be filed as of that date, including a report identifying any gaps between foreign persons that are subject to the EU and UK sanctions programs for Russia, but that are not yet sanctioned by OFAC. It doesn't appear that any such reports have yet been filed with Congress, at least not publicly? In a recent co-authored article with UK counsel Mikhail Vishnyakov FCIArb and Anna-Rose Davies of Cooke, Young & Keidan LLP, we had assessed this reporting requirement for the EU, UK, and US sanctions gap, and the coming wave of designations by OFAC on persons identified in the report. There is no stated requirement for the report or any portion thereof to be classified. However, even if not made public, it would be useful to know if it was at least filed with Congress. #ofac #russiasanctions #sanctionscompliance #eusanctions #uksanctions #sanctions #sanctionsscreening #mahsaact https://lnkd.in/drEtWGVi

Our legal briefing regarding the recently imposed US sanctions relating to #russia can be found below. It’s particularly important to note: - that OFAC sanctioned the National Payment Card System, JSC which will affect participants worldwide in Russia’s “Mir national payment system,”. Whilst unlikely to impact domestic Russia related transactions it’s understood Mir has also been used in other countries and so it will be interesting to see where Russia turns next for settlement services for card transactions; - the impact and potential increase of secondary sanctions risk for foreign financial institutions; and - the designation of various third country parties believed to have engaged in sanctions circumvention - a trend we are likely to continue to see going forward. https://lnkd.in/dDv8v4tB #sanctions #sanctionscompliance #russiaukrainewar Ginger Faulk Sarah Paul Mark Herlach Lamine Hardaway Nicholas T. Hillman Monika Zejden-Erdmann James Lindop Zia Ullah Robyn Brown Kimberly Jones Emma Middleton Adina Khan Matilde Hernandez Charlotte Duranté

KYC took on added significance in the sanctions world in 2023. No, not Know Your Customer, though that certainly remains important. Know Your Cargo became a new mantra for sanctions practitioners and there is every indication it will continue to be heard throughout 2024. But growing geopolitical tensions and national security concerns mean that trade-related sanctions will not be the only area of focus in 2024. Read more here: https://lnkd.in/epYPdTcC #kyc #knowyourcustomer #riskmanagement #protiviti Perry Huijgen Owen Roderik Strijland Yvonne van der Schoot

📣 U.S. Treasury Uncovers Sanctions Evasion Scheme Involving Russian Oligarch Oleg Deripaska 📅 On May 14, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) exposed a sanctions evasion scheme involving Russian oligarch Oleg Deripaska. ✅ OFAC designated Deripaska and three Russia-based companies attempting to unfreeze $1.5 billion in assets through complex transactions. Russian national Dmitrii Beloglazov and his firm, Titul, coordinated with Deripaska to sell his frozen shares via shell companies Iliadis and Rasperia. ⛔ This action blocks their assets and prohibits U.S. transactions with them, highlighting OFAC's commitment to enforcing sanctions and preventing illicit financial activities. Original source 👉: https://lnkd.in/eyrWSCuA #USsanctions #sanctionsupdate #sanctionscompliance #OFAC #SanctionsEvasion #OlegDeripaska #AML #RussiaSanctions #IllicitFinance

What are the latest developments in the trade sanctions world? Join our Sanctions+ Podcast and hear from our hosts Milana Karayanidi and Shahrzad Noorbaloochi, from our International Trade team, as they discuss: • The OFAC's February 23, 2024, Russia designation action. • Venezuela sanctions relief. • New actions targeting transfer of personal data to certain countries. • The expansion of export controls involving SDNs. Listen now: https://lnkd.in/gfde6BC3

What are the latest developments in the trade sanctions world? Join our Sanctions+ Podcast and hear from our hosts Milana Karayanidi and Shahrzad Noorbaloochi, from our International Trade team, as they discuss: • The OFAC's February 23, 2024, Russia designation action. • Venezuela sanctions relief. • New actions targeting transfer of personal data to certain countries. • The expansion of export controls involving SDNs. Listen now: https://lnkd.in/gjU3h8Du

Timely advice in a complicated geo-political environment. ⬇️

OFAC has issued scenario-based sanctions compliance guidance for the U.S. and international maritime industry. The guidance tracks five hypothetical scenarios depicting common sanctions evasion schemes encountered in the maritime industry. Read our summary below. https://bit.ly/3Z7UZKM