Meghan Hamilton, Author at Global Sanctions and Export Controls Blog

US Government Imposes Additional Financial Sanctions on Russia, Targeting Several Russian Banks and Russian Sovereign Debt

February 23, 2022 By Alison J. Stafford Powell, Alexandre (Alex) Lamy, Meghan Hamilton and Taylor Parker 6 Mins Read

On February 22, 2022, the US Government issued a number of additional sanctions measures against Russia in response to President Putin’s recognition of the independence of the “so-called Donetsk People’s Republic (DNR) and Luhansk People’s Republic in Ukraine (LNR)” and his request to deploy forces to those regions – with President Biden characterizing these developments as “the beginning of a Russian invasion of Ukraine.” The new US sanctions measures build on the comprehensive region-wide sanctions…

State Department Proposes Changes to ITAR Nationality Rule and Other Substantive Clarifications to ITAR

February 14, 2022 By Paul Amberg, Meghan Hamilton and Daniel Andreeff 2 Mins Read

On February 2, 2022, the Department of State published a proposed rule that, most significantly, would amend provisions of the International Traffic in Arms Regulations (“ITAR”) affecting how the nationality of foreign persons is determined for purposes of deemed exports/reexports. Specifically, the proposed rule would modify relevant portions of the definitions of export (ITAR §120.17) and reexport (ITAR §120.19) such that only a foreign person’s current citizenship(s) and current permanent residenc(ies) would need be taken…

Annual Increase in Civil Monetary Penalties for US Treasury, State, and Commerce Departments

February 14, 2022 By Kerry B. Contini and Meghan Hamilton 4 Mins Read

The US Treasury Department’s Office of Foreign Assets Control (“OFAC”), the US State Department (“State”), and the US Commerce Department (“Commerce”) issued rules adjusting maximum civil monetary penalties (“CMPs”) under the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015 (“FCA”), as outlined below. (For additional years of CMPs, see our previous blog post available here.) OFAC CMP Adjustments Under OFAC’s final rule published on February 9, 2022, the adjusted penalties apply to CMPs…

US Government Issues Executive Order Imposing Sanctions on Foreign Persons Involved in the Global Illicit Drug Trade and Adds Parties to the SDN List

December 17, 2021 By Bart M. McMillan, Meghan Hamilton and Taylor Parker 4 Mins Read

On December 15, 2021, President Biden issued Executive Order 14059, “Imposing Sanctions on Foreign Persons Involved in the Global Illicit Drug Trade” (“EO 14059”) aimed at addressing the trafficking of illicit drugs, including the illicit production, global sale and widespread distribution of drugs, in the United States. A press release issued by the Treasury Department explained that the additional authority under EO 14059 builds on the Treasury’s previous sanctions authorities, i.e., in Executive Order 12978…