On 14 June 2023, the UK Office of Financial Sanctions Implementation (“OSFI”) published updated guidance for the Maritime Services Ban and Oil Price Cap (the “Updated Guidance”). The Updated Guidance can be found here and our previous blog posts on UK Maritime Services Ban and Oil Price Cap can be found here and here. The Updated Guidance provides additional clarity and detail on the following: Wind-down periods: OFSI has introduced a 45-day wind-down period for…
How can companies prepare in an era of increased sanctions enforcement and investigations? In this video, partners Kerry Contini and Alex Lamy share their advice to companies navigating the rapidly evolving sanctions landscape. As rules become more restrictive, companies should brace themselves for increased compliance risks and routinely review their compliance programs. It is also critical to prepare for cross-border investigations that require a technical understanding of the nuanced rules and their interplay across multiple…
On June 1, 2023, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) added four (4) entities to the Specialty Designated Nationals (“SDN”) List under Executive Order 14098 (“EO 14098”) and issued four general licenses (“GLs”) authorizing certain transactions involving Sudan. For more information on EO 14098, see our previous blog post available here. We summarize the four GLs below that authorize certain activities and transactions involving SDNs designated under EO 14098.…
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…