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Meghan Hamilton

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On December 2, 2021, the EU, UK, US, and Canada all imposed additional coordinated sanctions on Belarus as a punitive action against the government led by President Alexander Lukashenko, which has been accused of human rights violations and creating a migrant crisis at Belarusian borders. As further described below, the sanctions included the designation of a number of parties (individuals and entities), whilst certain individuals will also be subject to travel bans preventing them entering…

On November 10, 2021, the US Departments of State, Treasury, and Commerce issued a joint advisory (the “Advisory”) cautioning US companies operating in or considering operations in Cambodia to be conscious of dealings with entities and in sectors potentially involved in human rights abuses, criminal activities, and corrupt business practices. We describe the Advisory in additional detail below. On the same day the Advisory was issued, the Treasury Department’s Office of Foreign Assets Control (“OFAC”)…

On October 15, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) published sanctions compliance guidance for the virtual currency industry (the “Guidance”), given that “the growing prevalence of virtual currency … brings greater exposure to sanctions risk.” This Guidance follows (1) the recent and first-ever designation of a virtual currency exchange (SUEX OTC, S.R.O) by the OFAC (see our recent post on this here), and (2) the launch of the National Cryptocurrency Enforcement…

On September 17, 2021, President Biden signed Executive Order 14046, “Imposing Sanctions on Certain Persons With Respect to the Humanitarian and Human Rights Crisis in Ethiopia” (“EO 14046”) aimed at addressing the widespread humanitarian conflict in northern Ethiopia. Both the White House and Secretary of State Antony J. Blinken also released statements found here and here, calling for ceasefire negotiations to begin to find a political solution to the ongoing conflict in the region and…