US trade sanctions and export controls targeting Iran have attracted increasing attention from Chinese companies doing business in Iran or with Iran counterparties. This client alert aims to provide a high-level overview on US trade sanctions and export controls targeting Iran, their implications (particularly in terms of their extraterritorial application), and the potential penalties that can be imposed on companies and their executives and employees in the event of violations.Read more…
Ukraine introduced martial law ending on 26 December 2018 in 10 regions of Ukraine bordering the Russian Federation, Belarus and Moldova’s Trans-Dniester area (Vinnytsia, Luhansk, Mykolaiv, Odesa, Sumy, Kharkiv, Chernihiv, Donetsk, Zaporizhia and Kherson regions), and in the internal waters of Ukraine in the Azov-Kerch water area.
On November 23, 2018 the Russian Government issued Decrees No. 1403, No. 1404, No. 1405 (“Decrees“), establishing the right of Russian banks and credit institutions that fall under foreign sanctions to not disclose certain information that is normally subject to mandatory disclosure requirements.
In particular, the Decrees prescribe such banks and credit institutions to provide information on its shareholders and UBOs only to the Central Bank of Russia and to give motivated explanations. The Central Bank of Russia is recommended to not disclose such information publicly.
According to the Russian Government, the above measures are intended to safeguard the interests of Russian banks and credit institutions that fall under sanctions imposed by foreign states.
The Decrees are expected to come into force on December 5, 2018.
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…