Author

Kerry B. Contini

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Over the past eight weeks, following the announcement of the G7’s Sanctions Enforcement Coordination Mechanism, we have journeyed to our offices in each of the G7 members to ask our local sanctions experts to weigh in on what companies should know about sanctions enforcement in their jurisdiction — and what companies should be doing today to prepare — in light of the increase in sanctions enforcement, which we are already seeing on the ground. For…

On March 24, 2023, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued a final rule amending and reissuing the Belarus Sanctions Regulations, 31 CFR part 548 (the “Regulations”), to implement Executive Order (“EO”) 14038, including Directive 1 issued pursuant to EO 14038. The final rule is effective as of March 27, 2023. OFAC had previously sanctioned certain Belarussian parties as a result of Belarus’ support for and facilitation of Russia’s invasion of…

Last week, among the flurry of new sanctions announcements marking the one-year anniversary of Russia’s large-scale invasion of Ukraine, the G7 announced the creation of a new Enforcement Coordination Mechanism “to bolster compliance and enforcement of our measures and deny Russia the benefits of G7 economies.” The International Group of Seven (“G7”) is an intergovernmental forum whose members include the US, UK, Germany, France, Italy, Canada, and Japan, with the European Union as a “non-enumerated”…

On February 17, the Bureau of Industry and Security (“BIS”) in the US Commerce Department announced that it is expediting the processing of export license applications for items needed to aid survivors of the earthquakes in Türkiye and Syria through NGOs.  While most items subject to the Export Administration Regulations (“EAR”) do not require licenses for export to Türkiye, Syria is subject to comprehensive US export controls and, as such, items subject to the EAR…