Inessa Owens

US and EU Authorize New Sanctions Targeting Turkey

October 18, 2019 by Ross L. Denton, Nicholas F. Coward, Inessa Owens, Laura Klick and Andrew Rose

On 14 October, the United States and European Union each adopted sanctions measures targeting Turkey, in response to Turkey’s military offensive in northern Syria. Subject to certain exceptions discussed further below, the US measures under a new Syria-related Executive Order (“New Syria EO“) took effect immediately and authorize sanctions targeting parties engaging in certain Syria-related activities, the Government of Turkey and Turkish Government officials, and certain sectors of the Turkish economy.

The EU measures are expected to come into effect shortly.

Ross L. Denton

Ross Denton is a Partner in the Firm’s EU, Competition and Trade Department in London. Ross was the former head of the Firm’s International Trade and WTO Practice Group, and now serves on the Firm’s Cartel Task Force. Ross also heads up the European Trade practice for the Firm. Ross routinely advises US and Japanese multinational corporations on competition law, export controls and sanctions, customs, bribery and corruption, and public procurement. Ross is a key member of the London office Anti-Bribery and Corruption Unit. Ross regularly speaks on trade and cartel issues, and has published widely on compliance related issues. He is a member of the UK Customs Practitioners Group.

Nicholas F. Coward

Mr. Coward focuses on outbound trade compliance matters, including the extraterritorial application of US law, particularly US export control laws, anti-boycott regulations and trade sanctions/embargoes maintained by the US government against various countries. In addition, his practice covers issues of corporate conduct such as the application of the Foreign Corrupt Practices Act and foreign bribery laws. He provides international transactional advice; assistance in the design and implementation of corporate compliance programs, compliance audits, and internal investigations; and representation in enforcement proceedings.

http://www.bakermckenzie.com/NickCoward

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

Laura Klick

Laura Klick is a US-qualified Associate in Baker McKenzie's London office, where she advises on a variety of trade and compliance matters involving US, UK, and EU export controls and economic sanctions. Laura regularly counsels individuals and multinational corporations on compliance, licensing, and enforcement matters involving the US Treasury, State, and Commerce Departments and assists clients in understanding and navigating the complex regulatory regime governing international trade and investment.

Andrew Rose

OFAC Issues Amended Venezuela-Related General Licenses to Extend Validity Periods for Dealings in Bonds and Securities

October 8, 2019 by Terence Gilroy, Inessa Owens and Meghan Hamilton

On September 30, 2019, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) amended two Venezuela-related general licenses (“GLs”), re-issued as General License 3G (“GL 3G”) and General License 9F (“GL 9F”), to extend the authorization for dealings in certain bonds and other securities, as further outlined below. Our blog post regarding previous amendments to these GLs is available here. Read more…

Terence Gilroy

Terry Gilroy is a partner in the New York office of Baker McKenzie and a member of the Compliance and Investigations Practice Group. Prior to joining the Firm in 2018, Terry served as Americas Head of the Financial Crime Legal function at Barclays. Terry advises businesses and individuals on white collar and financial crime issues and has significant experience conducting investigations relating to compliance with the US Foreign Corrupt Practices Act (FCPA) and related bribery and corruption statutes, economic sanctions regulations as administered by the US Department of the Treasury's Office of Foreign Assets Control (OFAC), and the Bank Secrecy Act and related anti-money laundering (AML) regulations and statutes. Terry spent six years on active duty in the United States Army as a Field Artillery officer.

https://www.bakermckenzie.com/en/people/g/gilroy-terence

Inessa Owens

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

BIS Issues Huawei-Related FAQs

September 16, 2019 by Janet K. Kim and Inessa Owens

On September 9, 2019, the US Commerce Department’s Bureau of Industry and Security (“BIS”) published two Frequently Asked Question (“FAQ”) documents (available here and here) on the Huawei Entity List and Temporary General License (“TGL”) and the Huawei TGL Extension (the amended TGL issued on August 21, 2019 is available here). See our blog post on the extension of the Huawei TGL here.

The key clarifications made by BIS in the two sets of FAQs include the following: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

http://www.bakermckenzie.com/en/people/o/owens-inessa

US Government Escalates Sanctions Against the Government of Venezuela

August 8, 2019 by Andrea Tovar, Inessa Owens, Janet K. Kim and Alison J. Stafford Powell

On August 5, 2019, President Trump issued Executive Order 13884 (“Venezuela EO”) blocking all property of the Government of Venezuela (“GOV”), a significant escalation of sanctions against the regime of President Maduro. Statements issued by the White House and State Department indicate that this escalation is meant to target the Maduro regime for its continued abuses of human rights and repression. The US Department of Treasury’s Office of Foreign Assets Control (“OFAC”) concurrently issued 12 amended general licenses and 13 new general licenses, new and revised FAQs, and guidance related to the provision of humanitarian assistance and support to the Venezuelan people.

The Venezuela EO targets only the GOV and entities owned 50% or more or otherwise controlled by the GOV, and thus does not place Venezuela under a full territorial embargo. Transactions with private Venezuelan parties that can be effected without the involvement of the GOV remain permissible.

The new sanctions prohibit virtually all US Person dealings with the GOV by blocking the property and interests in property of the GOV that are in the United States, that come within the United States, or that come within the possession or control of US Persons (i.e., US companies and their branches, US banks, US citizens and permanent resident aliens, any person physically located in the United States). GOV funds, contracts or other property interests that come into the possession or control of US Persons must be blocked and reported to OFAC.

Sanctions & Export Controls Update