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April 2015

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Earlier today, representatives of the P5+1 governments reported that negotiators have reached an understanding with Iran regarding the framework for an agreement addressing Iran’s nuclear program.  A fact sheet outlining the parameters of this understanding is available online here.  A comprehensive agreement remains to be written, but according to the agreed framework such an agreement will provide for the relaxation of certain US, EU, and UN sanctions targeting Iran if it is verified that Iran is abiding…

On April 1, 2015, President Obama issued an Executive Order (the “Cyber EO”) authorizing the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) to designate as Specially Designated Nationals (“SDNs”) certain persons that have engaged in “significant malicious cyber-enabled activities.”  No party has yet been designated under the Cyber EO.  OFAC has stated in its Frequently Asked Questions (FAQs) that the Cyber EO is “intended to address situations where, for jurisdictional or other issues,”…

In the 2015 UK Budget, delivered on Wednesday 18 March, the UK government announced plans to “review the structures within HM Treasury for the implementation of financial sanctions and its work with the law enforcement community to ensure these sanctions are fully enforced, with significant penalties for those who circumvent them”. This review will focus on how the UK can implement and enforce financial sanctions effectively in its national security interests, taking into consideration…

Australia imposed targeted financial sanctions and travel bans relating to Russia against designated persons and entities in June and September 2014.  Expanded sanctions were announced in September 2014. Following a consultation period, the expanded regime has just taken effect. The expanded sanctions restrict: export to and import from Russia of arms and related materiel; export to Russia of specified items for use in petroleum exploration and production; export to Crimea and Sevastopol of specified…