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Paul Amberg

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The sanctions enforcement storm is underway. As we highlighted in the introduction to this blog series, the quickly evolving sanctions landscape of recent years has increased the complexity of compliance. Keeping up with ever-changing multi-jurisdictional sanctions and adapting compliance practices has proven challenging for companies with complex operations and supply chains. Instances of non-compliance can be inevitable. A company’s investigation triage plan should evaluate mandatory disclosure obligations and, if there are none, the availability and…

On April 29, 2024, the European Union (“EU”) adopted the Directive (EU) 2024/1226 on the definition of criminal offenses and penalties for the violation of Union restrictive measures and amending Directive (EU) 2018/1673 (“Directive”). Member States will have until April 30, 2025 to transpose it into national legislation. The Directive defines criminal offenses and penalties and establishes minimum rules concerning the prosecution of violations or circumvention of EU sanctions in Member States and directs Member…

On April 18, 2024, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) and the UK’s Foreign, Commonwealth & Development Office (“FCDO”) announced a coordinated sanctions package targeting Iran. In the US, OFAC added 16 individuals and 10 entities to the Specially Designated Nationals and Blocked Persons List (“SDN List”) and the US Commerce Department’s Bureau of Industry and Security (“BIS”) also expanded the scope of Foreign Direct Product (“FDP”) rules for foreign-produced items…

On 18 December 2023, the EU published its 12th package of sanctions targeting Russia. The changes implemented in this package have a material impact on all businesses with a continued or residual presence in Russia, including those seeking to exit and divest from Russia. Moreover, all companies, even those not trading directly with Russia, should be mindful of the increased focus on targeting circumvention.In our latest on-demand webinar, we provide you with an overview of some…