Companies caught in the eye of the sanctions enforcement storm can only begin to effectively weather it by conducting a thorough internal investigation. These investigations are multifaceted (see our other blog posts in this series here), but an essential component is often conducting interviews. Interviews are a fundamental part of cross-border sanctions investigations that combine practical and legal challenges. Organizing them effectively requires an appreciation of practices in different jurisdictions, including local laws, customs, and…
On December 5, 2023 and December 6, 2023, respectively, the US and UK Governments announced new sanctions and export control measures targeting Russia focused on persons and entities in third countries supporting Russia’s military and defense industrial base and its war in Ukraine. US Sanctions and Export Control Updates The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced sanctions targeting a network led by Belgium-based individual, Hans De Geetere, as well…
The EU has published an update to its list of goods regarded as “economically critical” to Russia. Amongst these are hydraulic power engines and motors, concrete or mortar mixers, and machinery for public works. The amended list can be found here.
On 23 October, the European Council adopted a new framework for restrictive measures against Niger which seek to “sanction those who undermine the stability, democracy, rule of law in Niger, and constitute a threat to peace and security in the region” in response to the July 2023 military coup in Niger. The sanctions consist of asset freezes, and the related prohibition to make funds available to targeted individuals and entities, as well as travel bans…