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…
On September 21, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued an updated ransomware advisory (“Updated Advisory”) highlighting the sanctions risks associated with ransomware payments in connection with malicious cyber-enabled activities and the proactive steps companies can take to mitigate such risks, including actions that OFAC would consider to be “mitigating factors” in any related enforcement action. OFAC concurrently designated SUEX OTC, S.R.O. (“SUEX”) as a Specially Designated National (“SDN”), the first…
In recent weeks, the US Government has imposed a series of additional sanctions against Russia consisting of additional measures focused on the energy pipeline sector, as well as further measures in response to the alleged poisoning of Alexy Navalny. This latest escalation of sanctions against Russia builds upon the April 2021 sanctions imposed pursuant to Executive Order 14024, “Blocking Property With Respect to Specified Harmful Foreign Activities of the Government of the Russian Federation.” Please…
On July 19, 2021, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) published a final rule (“Final Rule”) adding six Russian organizations to the Entity List. These designations are related to Executive Order 14024, “Blocking Property With Respect To Specified Harmful Foreign Activities of the Government of the Russian” (“EO 14024”) that was signed by President Biden in April 2021. EO 14024 authorizes the imposition of sanctions in response to Russian efforts…