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The sanctions enforcement storm is underway. As we highlighted in the introduction to this blog series, the quickly evolving sanctions landscape of recent years has increased the complexity of compliance. Keeping up with ever-changing multi-jurisdictional sanctions and adapting compliance practices has proven challenging for companies with complex operations and supply chains. Instances of non-compliance can be inevitable. A company’s investigation triage plan should evaluate mandatory disclosure obligations and, if there are none, the availability and…

On May 1, 2024, the US Department of the Treasury’s Office of Foreign Assets Controls (“OFAC”) and the US Department of State designated nearly 300 individuals, entities, and vessels to the List of Specially Designated Nationals and Blocked Persons (“SDN List”) mainly targeting Russia’s military capacity. On the same day, OFAC also issued three new general licenses (“GLs”) authorizing limited transactions involving certain SDNs. We summarize these developments below. SDN Designations According to OFAC’s press…

On May 2, 2024, the Ministry of Trade of Türkiye announced on its official X account that Türkiye implements complete export and import restriction against Israel effective immediately. This decision was made following the export restriction imposed on April 9, 2024 by Türkiye against Israel targeting 54 product groups, such as electric panels, aluminum wires, cement, sulfur, ceramics, marble, varnishes, and mineral fertilizers. The announcement of the Ministry of Trade can be reviewed on the official…

On December 11, 2023, the US Departments of Commerce, the Treasury, Justice, State, and Homeland Security issued a “Quint-Seal” Compliance Note titled Know Your Cargo: Reinforcing Best Practices to Ensure the Safe and Compliant Transport of Goods in Maritime and Other Forms of Transportation (“Note”). The Note is directed at the maritime and other transportation industries—including transportation companies, maintenance companies, insurance providers, financial institutions, and “other entities involved in funding and facilitating the transport of…