On August 14, 2023, the US State Department, the Labor Department, and the Commerce Department issued a business advisory (“Business Advisory”) highlighting key risks for companies operating in South Sudan. While it does not impose new legal obligations on companies, the Business Advisory highlights the fact that list-based sanctions remain in force targeting certain South Sudanese persons including designations under the US Treasury Department’s Office of Foreign Assets Control’s Specially Designated Nationals and Blocked Persons List, and…
On May 4, 2023, the President Biden issued Executive Order 14098 (“EO 14098”) establishing a sanctions authority that authorizes the US Government to imposes sanctions on persons or entities in Sudan in connection with “the military’s seizure of power in October 2021 and the outbreak of inter-service fighting in April 2023.” While no sanctions have been imposed under EO 14098 to date, this new Sudan sanctions authority authorizes the US Government to issue asset blocking…
In recent weeks, there have been a number of noteworthy developments highlighting the increasing focus that US, EU, UK and other governments are placing on the potential circumvention of sanctions against Russia, and the roles of third countries and companies in facilitating the circumvention or undermining of such sanctions measures. These anti-circumvention efforts are taking place in the context of the G7’s concerted effort to bolster sanctions enforcement around the world, through the creation of…
On March 7, 2022, the US Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued an alert to financial institutions warning about potential attempts to evade US sanctions and other restrictions imposed on Russia and Belarus (“Alert”). The Alert includes red flags that financial institutions should review to help identify potential attempts to avoid sanctions, with a particular focus on convertible virtual currency (“CVC”), and also reminds companies of their reporting obligations under the Bank Secrecy…