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Sanctions Update: Sectoral Sanctions Against Russia Escalate
October 16, 2014
The United States and European Union implemented increased Ukraine-related sanctions against the Russian Federation on Sept. 12. The U.S. Treasury Department and its Office of Foreign Assets Control imposed new sanctions and strengthened existing sanctions in Russia’s financial and energy sectors. They also determined that persons operating within Russia’s defense and related materiel sector may now be subject to targeted sanctions under Executive Order 13662. In this article, SRZ attorneys Betty Santangelo, Gary Stein and former SRZ attorneys Nora Lovell Marchant and Lisa A. Prager examine the details of this recent round of sanctions.
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Alerts
On March 6, 2024, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), the US Department of Justice (“DOJ”) and the US Department of Commerce (collectively, the “Agencies”) published their latest in a series of Tri-Seal Compliance Notes in which they emphasized that foreign-based persons have an obligation to comply with US sanctions and export controls.[1] The Compliance Note does not reflect any policy change, but serves as a reminder that the Agencies have enforced sanctions and export controls against non-US persons, and highlights that non-US firms should implement measures to mitigate their risk of violating US laws. The Compliance Note also comes just a few months after the issuance of Executive Order (“E.O.”) 14114, which authorizes OFAC to sanction foreign financial institutions that engage in significant transactions with Russia’s military-industrial sector.[2] Below, we focus on the Compliance Note’s description of transactions in which OFAC has asserted authority to bring enforcement actions against non-US persons for sanctions violations and summarize some key implications for non-US fund managers.
Alerts
The US Securities and Exchange Commission (“SEC”) and the Commodity Futures Trading Commission (“CFTC”) have overhauled Form PF and private fund managers have until March 12, 2025, to begin reporting on the new Form. The changes to the reporting requirements mandated by the amendments to the Form (“Form PF Amendments”) will require substantial preparation by many managers.[1]
Alerts
On March 6, 2024, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), the US Department of Justice (“DOJ”) and the US Department of Commerce (collectively, the “Agencies”) published their latest in a series of Tri-Seal Compliance Notes in which they emphasized that foreign-based persons have an obligation to comply with US sanctions and export controls.[1] The Compliance Note does not reflect any policy change, but serves as a reminder that the Agencies have enforced sanctions and export controls against non-US persons, and highlights that non-US firms should implement measures to mitigate their risk of violating US laws. The Compliance Note also comes just a few months after the issuance of Executive Order (“E.O.”) 14114, which authorizes OFAC to sanction foreign financial institutions that engage in significant transactions with Russia’s military-industrial sector.[2] Below, we focus on the Compliance Note’s description of transactions in which OFAC has asserted authority to bring enforcement actions against non-US persons for sanctions violations and summarize some key implications for non-US fund managers.
Alerts
The US Securities and Exchange Commission (“SEC”) and the Commodity Futures Trading Commission (“CFTC”) have overhauled Form PF and private fund managers have until March 12, 2025, to begin reporting on the new Form. The changes to the reporting requirements mandated by the amendments to the Form (“Form PF Amendments”) will require substantial preparation by many managers.[1]
Alerts
On March 6, 2024, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), the US Department of Justice (“DOJ”) and the US Department of Commerce (collectively, the “Agencies”) published their latest in a series of Tri-Seal Compliance Notes in which they emphasized that foreign-based persons have an obligation to comply with US sanctions and export controls.[1] The Compliance Note does not reflect any policy change, but serves as a reminder that the Agencies have enforced sanctions and export controls against non-US persons, and highlights that non-US firms should implement measures to mitigate their risk of violating US laws. The Compliance Note also comes just a few months after the issuance of Executive Order (“E.O.”) 14114, which authorizes OFAC to sanction foreign financial institutions that engage in significant transactions with Russia’s military-industrial sector.[2] Below, we focus on the Compliance Note’s description of transactions in which OFAC has asserted authority to bring enforcement actions against non-US persons for sanctions violations and summarize some key implications for non-US fund managers.