The Court of Appeal handed down its judgment in the case of Lamesa Investments Ltd v Cynergy Bank Ltd [2020] EWCA Civ 281 on 30 June 2020. The case appealed a 2019 High Court judgment that found that Cynergy Bank Limited was entitled to refuse to pay interest payments to Lamesa Investments Ltd, under a facility agreement, due to a concern that Cynergy would be subject to US secondary sanctions (please see our previous blog…
On 19 March 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) sanctioned five companies based in the United Arab Emirates (“UAE”), pursuant to Executive Order 13846 (“EO 13846”), for their alleged involvement in purchasing hundreds of thousands of metric tons of petroleum products from the National Iranian Oil Company (“NIOC”) for delivery to the UAE. The following UAE-based companies were added to the US Specially Designated Nationals and Blocked Persons List (“SDN List”):…
On October 25, 2019, the US Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued a final rule identifying Iran as a jurisdiction of primary money laundering concern (“Final Rule”) under Section 311 of the USA PATRIOT ACT, seeking to further isolate Iran from the global financial system. Concurrently, the US Treasury and State Departments announced a new humanitarian mechanism to ensure that funds associated with permissible trade in support of the Iranian people are not diverted by the Iranian regime to develop ballistic missiles, support terrorism, or finance other malign activities. These measures build upon the US Treasury Department’s Office of Foreign Assets Control’s (“OFAC”) additional sanctions against the Central Bank of Iran discussed in our prior blog post here.
On October 17, 2019, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) re-issued and amended as General License No. 13D (“GL 13D”) to continue the validity period for transactions concerning Nynas AB and its affiliates (“Nynas”), as further described below. In addition, on October 21, 2019, OFAC re-issued as General License No. 8D (“GL 8D”) to continue the validity period certain maintenance activities involving Petróleos de Venezuela S.A. (“PdVSA”) where certain entities are involved, as further described below. Finally, on October 24, 2019, OFAC re-issued and amended as General License No. 5A (“GL 5A”) to prohibit dealings or payments for three months related to a specific PdVSA bond. Our blog post regarding previous amendments to these GLs is available here.