Baker McKenzie

US Government Imposes Economic Sanctions on Nicaragua Targeting Certain Individuals

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On November 27, 2018, the President signed Executive Order 13851 targeting Nicaragua entitled “Blocking Property of Certain Persons Contributing to the Situation in Nicaragua” (“Nicaragua EO”) available here.  The US Treasury Department’s Office of Foreign Assets Control (“OFAC”) also issued a press release related to the Nicaragua EO available here, and added two close associates of Nicaraguan President Daniel Ortega to the Specially Designated Nationals and Blocked Persons List (“SDN List”) pursuant to the new Nicaragua EO, the notice for which is available here.  The two new SDNs are the current Vice President of Nicaragua and President Ortega’s wife, Rosario Maria Murillo de Ortega, and President Ortega’s national security adviser, Nestor Moncada Lau.Read more…

Bart M. McMillan
Mr. McMillan's practice involves compliance counseling; compliance programs; licensing; compliance reviews; internal investigations; voluntary disclosures; administrative enforcement actions; criminal investigations; customs inquiries, audits, detentions, and seizures; and trade-compliance due diligence and post-acquisition integration in mergers and acquisitions. His practice includes matters that implicate the US International Traffic in Arms Regulations (ITAR), US Export Administration Regulations (EAR), US National Industrial Security Program (NISP), the US Committee on Foreign Investment in the United States (CFIUS), and equivalent non-US laws. Mr. McMillan regularly advises on and represents clients in matters involving technology, including its control, protection, accidental disclosure, diversion, or unauthorized collection. Mr. McMillan has extensive experience working with companies in the aerospace and defense industry, as well as companies in the Middle East and other parts of Asia.
http://www.bakermckenzie.com/BartMcMillan
Inessa Owens
Inessa Owens is an associate in the Washington, D.C. office and member of the Firm’s International Trade practice group. She focuses on outbound trade compliance issues, including compliance with the Export Administration Regulations, anti-boycott rules, and economic sanctions administered by the US Treasury Department’s Office of Foreign Assets Control, including those targeting Cuba, Iran, North Korea, Syria, and Russia. She has worked with clients in diverse industries that include finance, pharmaceuticals, and energy.
http://www.bakermckenzie.com/en/people/o/owens-inessa
Meghan Hamilton
Meg's practice involves assisting multinational companies with export compliance related matters, specifically trade sanctions and export control classifications. Additionally, she assists companies with respect to customs laws, anti-boycott laws and other trade regulation issues in the US and abroad. She also helps obtain authorizations from the US government for activities subject to sanctions regulations and US export control regulations, including the Export Administration Regulations and the International Traffic in Arms Regulations. Meg's practice extends to assistance in internal compliance reviews as well as enforcement actions and disclosures necessitated by US government action.
http://www.bakermckenzie.com/en/people/h/hamilton-meghan

OFAC Extends Expiration Date of General Licenses Related to RUSAL, EN+ Group, and GAZ Group and Imposes Secondary Sanctions on Parties Supporting Russia’s Occupation of Crimea

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Extension of General Licenses

On November 9, 2018, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) temporarily extended the expiration dates of four general licenses related to EN+ Group PLC (“EN+”), United Company RUSAL PLC (“RUSAL”), and GAZ Group (“GAZ”) from December 12, 2018 to January 7, 2019.  Please see our blog posts on the original designation of these companies and previous extensions of these general licenses here and here.  The Treasury Department press release indicates that EN+, RUSAL, and GAZ are proposing substantial corporate governance changes that could potentially result in significant changes in control and ultimately lead to these entities’ removal from the Specially Designated Nationals and Blocked Persons List (“SDN List”).Read more…

Paul E. Amberg
Paul Amberg is a partner in Baker McKenzie’s Amsterdam office, where he handles international trade and compliance issues. He advises multinational companies on export controls, trade sanctions, antiboycott rules, customs laws, anticorruption laws, and commercial law matters. Paul helps clients assess and address compliance risks presented by export controls, trade sanctions, antiboycott rules, customs laws, and anticorruption laws. His practice especially focuses on internal reviews, voluntary disclosure filings, and enforcement actions brought by, the US Government in relation to the Export Administration Regulations (EAR), International Traffic in Arms Regulations (ITAR), trade and economic sanctions programs, and US customs laws.
http://www.bakermckenzie.com/PaulAmberg
Inessa Owens
Inessa Owens is an associate in the Washington, D.C. office and member of the Firm’s International Trade practice group. She focuses on outbound trade compliance issues, including compliance with the Export Administration Regulations, anti-boycott rules, and economic sanctions administered by the US Treasury Department’s Office of Foreign Assets Control, including those targeting Cuba, Iran, North Korea, Syria, and Russia. She has worked with clients in diverse industries that include finance, pharmaceuticals, and energy.
http://www.bakermckenzie.com/en/people/o/owens-inessa
Andrea Tovar
Andrea practices international commercial law with a focus on cross-border transactions including post-acquisition integration IP migrations and technology licensing. She also advises companies on export controls, sanctions, customs and international corporate compliance. Andrea also has an active pro bono practice, including helping organizations with international constitutional matters and victims of domestic abuse.
https://www.bakermckenzie.com/en/people/t/tovar-andrea

US Government Sanctions Chinese Entity for Engaging in Transactions with Russian Defense Sector Under CAATSA Section 231 List, Clarifies CBW Act Waiver, and Extends Expiration of General Licenses Related to RUSAL and EN+ Group

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In the past week, the US Government took several significant steps related to the US sanctions against Russia.  These included imposing sanctions pursuant to Section 231 of the Countering America’s Adversaries Through Sanctions Act (“CAATSA”) for the first time and expanding the list of persons and entities identified as being part of the Russian defense or intelligence sectors under CAATSA Section 231.  The US Government also clarified the scope of a sanctions waiver impacting foreign subsidiaries in Russia under the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (the “CBW Act”).  Finally, the US Government extended the expiration dates for several general licenses related to United Company RUSAL PLC (“RUSAL”) and EN+ Group PLC (“EN+ Group”).Read more…

Kerry B. Contini
Ms. Contini focuses her practice on export controls, trade sanctions, and anti-boycott laws. This includes advising US and multinational companies on trade compliance programs, risk assessments, licensing, review of proposed transactions and enforcement matters. Ms. Contini works regularly with companies across a wide range of industries, including the pharmaceutical/medical device, oil and gas, and nuclear sectors.
http://www.bakermckenzie.com/KerryContini
Inessa Owens
Inessa Owens is an associate in the Washington, D.C. office and member of the Firm’s International Trade practice group. She focuses on outbound trade compliance issues, including compliance with the Export Administration Regulations, anti-boycott rules, and economic sanctions administered by the US Treasury Department’s Office of Foreign Assets Control, including those targeting Cuba, Iran, North Korea, Syria, and Russia. She has worked with clients in diverse industries that include finance, pharmaceuticals, and energy.
http://www.bakermckenzie.com/en/people/o/owens-inessa
Daniel Andreeff
Daniel Andreeff’s practice focuses on US economic and trade sanctions, including those targeting Iran, Russia, Cuba, Syria, and North Korea, export controls, and anti-boycott laws. He represents clients in national security reviews before the Committee on Foreign Investment in the United States (CFIUS), and has experience in federal court litigation and congressional investigations. His pro bono practice includes providing sanctions and export control advice to a global humanitarian NGO. * Admitted in New York only. Practice in the District of Columbia is under the supervision of a member of the District of Columbia Bar.
https://www.bakermckenzie.com/en/people/a/andreeff-daniel

First Iran Sanctions Wind-Down Period Ends and President Trump Issues New Iran Sanctions Executive Order

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On August 6, 2018, President Trump issued Executive Order 13846, “Reimposing Certain Sanctions with Respect to Iran” (the “New Iran EO”), which formally reimposes certain sanctions on Iran that had been suspended or revoked as part of the United States’ commitments under the Joint Comprehensive Plan of Action (“JCPOA”). The New Iran EO, which was issued to coincide with the end of the 90-day wind-down period announced on May 8, 2018 and detailed in our previous blog post, reimposes a wide range of sanctions on Iran that were in effect prior to the implementation of the JCPOA pursuant to pre-existing legal authorities, and also expands the scope of those sanctions, as described below. Read more…

Janet K. Kim
Ms. Kim focuses on outbound trade compliance issues that arise under US economic sanctions, export control laws, investment restrictions, anti-boycott regulations, anti-money laundering laws and the Foreign Corrupt Practices Act. She represents and advises US and non-US companies in criminal and regulatory proceedings, internal investigations, and compliance audits relating to these areas of law. She also advises on the extraterritorial application of these laws in cross-border transactions, including mergers and acquisitions, joint venture arrangements, and other international commercial activities. Her practice includes the development and implementation of workable, risk-based internal compliance programs and procedures for companies in a wide range of industries.
http://www.bakermckenzie.com/JanetKim
Inessa Owens
Inessa Owens is an associate in the Washington, D.C. office and member of the Firm’s International Trade practice group. She focuses on outbound trade compliance issues, including compliance with the Export Administration Regulations, anti-boycott rules, and economic sanctions administered by the US Treasury Department’s Office of Foreign Assets Control, including those targeting Cuba, Iran, North Korea, Syria, and Russia. She has worked with clients in diverse industries that include finance, pharmaceuticals, and energy.
http://www.bakermckenzie.com/en/people/o/owens-inessa
Daniel Andreeff
Daniel Andreeff’s practice focuses on US economic and trade sanctions, including those targeting Iran, Russia, Cuba, Syria, and North Korea, export controls, and anti-boycott laws. He represents clients in national security reviews before the Committee on Foreign Investment in the United States (CFIUS), and has experience in federal court litigation and congressional investigations. His pro bono practice includes providing sanctions and export control advice to a global humanitarian NGO. * Admitted in New York only. Practice in the District of Columbia is under the supervision of a member of the District of Columbia Bar.
https://www.bakermckenzie.com/en/people/a/andreeff-daniel


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