Since we published our blog post on the relaxation of the Syria sanctions over the weekend, there have been two more related developments this week: (1) US guidance on the Syria sanctions relaxed on Friday, May 23, and (2) the EU’s move to formally lift nearly all of its remaining sanctions on Syria. United States: Guidance on Syria Sanctions Relaxation On Wednesday, May 28, the Office of Foreign Assets Control (“OFAC”) in the US Treasury…
On January 10, 2025, in a multilateral sanctions action, the US, Canada, EU, and UK sanctioned various Venezuelan individuals linked to the Venezuelan government and prominent state-owned entities. US Sanctions The US Treasury Department’s Office of Foreign Assets Control (“OFAC”) designated eight Venezuelan individuals as Specially Designated Nationals pursuant to Executive Order 13692, including the president of the Specially Designated National state-owned petroleum company, Petroleos de Venezuela, S.A., (PdVSA), the Venezuelan Ministry of Transportation and…
On 16 December 2024, the EU introduced its 15th package of sanctions against Russia, including by amending Regulation (EU) 833/2014 and Regulation (EU) 269/2014. The EU also issued the first designations under its “hybrid threats” sanctions framework, which was announced in early October 2024. Finally, the EU designated individuals and entities pursuant to EU sanctions against Belarus (Regulation (EC) No 765/2006). This latest round of sanctions entered into force on 17 December 2024 and is…
As regulations evolve and enforcement intensifies, effective documentation of sanctions investigation results has never been more critical. Proper documentation is crucial not only for maintaining legal privileges and the confidentiality of sensitive information, but also for supporting legal defenses in potential regulatory enforcement in the future. Additionally, companies may have an obligation to disclose investigation results to their external auditors, shareholders, and other stakeholders (e.g., transaction counterparties), underscoring the importance of appropriate documentation to ensure…