Event 14 Oct. 2022
Curtis Provides Capacity Training to the Government of Uganda
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Event 21 Sep. 2022
Kalidou Gadio Speaks at AIEN 2022 International Energy Summit
News 15 May. 2023
Curtis represents e-commerce retailer in its fight to recover monies withheld by PayPal, the global payment giant
News 16 Dec. 2022
Curtis Trade Team is top ranked in Chambers Asia-Pacific 2023
Event 08 May. 2023
Partner Irene Petrelli to Participate in ICC YAAF Event
News 02 May. 2023
Curtis Italy with DeA Capital in the Acquisition of Magic S.r.l
Event 23 May. 2023
Partners Luciana Ricart and Fernando Tupa Will Teach a Workshop on Hearings in Investment Arbitration for Arbanza School of Arbitration’s Online Program
Publications 23 Feb. 2023
Fernando Tupa Publishes Book on Forum-Specific Consent to International Arbitration in Investment Agreements
Event 03 May. 2023
Dr. Borzu Sabahi to Speak at ICSID-ADGM Joint Conference: Investment Protection and Armed Conflict
News 27 Sep. 2022
Curtis Boosts Riyadh Office with New Corporate Partner Stuart Davies
News 25 May. 2023
Curtis Files SCOTUS Amicus Brief for Distinguished Law Professors in First Amendment Retaliatory Arrest Case
News 06 Mar. 2023
Russia Sanctions at the First Anniversary: An Overview of Current Sanctions in the US, UK, and EU and How Global Companies Can Navigate Evolving and Conflicting Sanctions Regimes
Client Alert 30 Aug. 2022
The EU Adopts the “Maintenance and Alignment” Sanctions Package
Client Alert 24 Jun. 2021
Update on Virtual Notarization (Executive Order 202.7) During the COVID-19 (Coronavirus) Pandemic (Updated: June 24, 2021) — U.S. Insight
Update on Virtual Witnessing (New York Executive Order 202.14) During The COVID-19 (Coronavirus) Pandemic (Updated: June 24, 2021) — U.S. Insight
Client Alert 11 Mar. 2022
Click here to download the full alert
On February 24, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) released a second tranche of sanctions against Russian individuals and entities. These measures followed the comprehensive jurisdiction-based sanctions imposed on DNR and LNR on February 21, 2022, sanctions related to the Russian financial sector imposed on February 22, 2022, and sanctions on Nord Stream 2 G imposed on February 23, 2022.
The second tranche includes two new directives. OFAC Directive 2, issued under E.O. 14024, prohibits U.S. financial institutions from opening or maintaining a correspondent account or payable-through account for or on behalf of PJSC Sberbank of Russia and 25 of its subsidiaries, effective March 26, 2022. Processing transactions involving Sberbank and its subsidiaries is also prohibited. OFAC may designate other foreign financial institutions under Directive 2. Sanctions against such financial institutions shall become effective 30 days after the designation.
OFAC Directive 3, also issued under E.O. 14024, prohibits U.S. persons from engaging in all transactions in, providing financing for, and other dealings in new debt of longer than 14 days’ maturity or new equity issued on or after 12:01 a.m. Eastern Daylight Time, March 26, 2022, by 13 Russia-related entities:
OFAC defines debt to include “bonds, loans, extensions of credit, loan guarantees, letters of credit, drafts, bankers acceptances, discount notes or bills, or commercial paper” and equity to include “stocks, share issuances, depositary receipts, or any other evidence of title or ownership.”
OFAC may designate other foreign entities under Directive 3, which will be named on OFAC’s CAPTA List. Sanctions against such financial institutions shall become effective 30 days after the designation.
Additions to the SDN List
On February 24, 2022, OFAC also added approximately 70 individuals and entities to the SDN List pursuant to E.O. 14024. A full list is available here.
Enforcement
The U.S. Department of Justice announced a new task force aimed at enforcing sanctions on Russian oligarchs. Task Force KleptoCapture will be led by Andrew Adams, a veteran Assistant U.S. Attorney for the Southern District of New York. The interagency law enforcement group will be responsible for investigating and prosecuting sanctions violations.
The task force will be run out of the Office of the Deputy Attorney General, and will include attorneys from the National Security, Criminal, Tax and Civil Divisions of the Department of Justice, as well as from U.S. Attorneys’ Offices across the country. The task force will also include agents and analysts from the Federal Bureau of Investigation, the U.S. Marshals Service, the Internal Revenue Service, the Postal Inspection Service, the Department of Homeland Security, the Secret Service, and other agencies.
The Department of Justice announced that Task Force KleptoCapture will cooperate with a transatlantic task force that was announced by President Biden and European allies on February 26, 2022.
No further information about the transatlantic task force has been made available.
Economic Sanctions
International Trade
Ana Amador
Associate
Lorena Guzmán-Díaz
Jason D. Wright
Partner
Marwa Farag
John Taishu Pitt
Trade Analyst
New York
+1 212 696 6000
Washington, D.C.
+1 202 452 7373
Brussels
+32 2 313 37 31
Geneva
+41 22 718 3500
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EU/UK Expand Sanctions against Russia
Client Alert 07 Mar. 2022
U.S. President Biden Imposes Export Controls on Russia and Belarus
Client Alert 01 Mar. 2022
EU and the UK Impose Further Sanctions on Russia
Client Alert 24 Feb. 2022
EU, UK, Japan and Australia Impose Sanctions on Russia
Client Alert 23 Feb. 2022
OFAC Imposes Sanctions on Russian Persons, Entities, and Vessels
Client Alert 22 Feb. 2022
President Joseph Biden Issues Executive Order Imposing U.S. Sanctions Against Russia Backed Regions in Eastern Ukraine
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