Event 14 Jun. 2022
Antonia Birt to Speak on Importance of Going Paperless in Arbitration Proceedings at Upcoming Webinar
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Event 02 Jun. 2022
Borzu Sabahi Lectures to Government Officials from Ghana and Kenya
Client Alert 29 Jun. 2022
Discovery, Jurisdiction and Service: Changes in U.S. Law and Implications for Japanese Companies
Client Alert 24 Feb. 2022
EU, UK, Japan and Australia Impose Sanctions on Russia
News 05 Jul. 2022
Sebastiano Nessi Joins Curtis’ International Disputes Practice as Partner in Geneva
Publications 30 Jun. 2022
Lise Johnson’s Submission to the OECD's Public Consultation on Investment Treaties and Climate Change
Event 08 Jun. 2022
Partner Fernando Tupa Speaks at Instituto Peruano de Arbitraje’s Second International Conference on Arbitration and Energy
Claudia Frutos-Peterson Speaks at the 13th Latin American Arbitration Conference (CLA)
Dubai Partner Antonia Birt to Moderate Panel on Hybrid Legal Cultures in International Arbitration
News 01 Jul. 2022
Partner Charles Howland Quoted in Spotlight PA Article on PFAS Groundwater Contamination
Client Alert 30 Jun. 2022
U.S. President Biden Issues Eighth Tranche of Economic Sanctions
Client Alert 28 Jun. 2022
U.S. President Biden Raises Tariffs on Russian Imports
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 23 May. 2022
Click here to download the full client alert
On May 8, 2022, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued a Determination prohibiting the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of accounting, trust and corporate formation, and management consulting services to any person located in the Russian Federation. In tandem with that, OFAC issued a Determination imposing economic sanctions on any person determined by the Secretary of the Treasury, in consultation with the Secretary of State, or by the Secretary of State, to operate or to have operated in the accounting, trust and corporate formation, or management consulting sectors of the Russian economy.
OFAC also released new general licenses related to telecommunications. OFAC and the State Department have made new designations.
In a Determination pursuant to E.O. 14071, OFAC has specifically prohibited the “exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of accounting, trust and corporate formation, or management consulting services to any person located in the Russian Federation.” The prohibition will take effect at 12:01 a.m. Eastern Daylight Time (EDT) on June 7, 2022.
FAQ 1034 and 1035 define the prohibited services as follows:
The prohibitions will not apply to the following entities:
This is OFAC’s first E.O. 14071 Determination. Curtis will monitor any future developments.
In conjunction with the E.O. 14071 Determination, OFAC issued two general licenses authorizing certain wind down transactions related to these services.
In a Determination pursuant to E.O. 14024, issued in parallel with the E.O. 14071 Determination, OFAC has determined that section 1(a)(i) of E.O. 14024 applies to “the accounting, trust and corporate formation services, and management consulting sectors of the Russian Federation economy.”
FAQ 1037 clarifies that a “sector determination pursuant to E.O. 14024 exposes persons that operate or have operated in an identified sector to sanctions risk; however, a sector determination does not automatically impose sanctions on all persons who operate or have operated in the sector. Only persons determined, pursuant to E.O. 14024, by the Secretary of the Treasury in consultation with the Secretary of State, or by the Secretary of State, in consultation with the Secretary of the Treasury, or their delegates, to operate or have operated in the above-identified sectors are subject to sanctions.”
Therefore, while the E.O. 14024 Determination will take effect immediately on May 8, 2022, it does not apply to any person in these sectors until there has been a designation. There has been no such designation to date specifically related to the abovementioned service sectors.
OFAC also updated and reissued General License 25A and issued General License 33:
Pursuant to E.O. 14024, OFAC has designated the following persons and entities that are “critical to Russia’s ability to wage war against Ukraine”:
The State Department has also designated the following entities pursuant to E.O. 14024 Section 1(a)(i) in the maritime sector:
Curtis will continue to monitor developments in this rapidly changing area.
Economic Sanctions
National Security Law
International Trade
Jacques Semmelman
Partner
Jason D. Wright
Ana Amador
Associate
Marwa Farag
Lorena Guzmán-Díaz
John Taishu Pitt
Trade Analyst
New York
+1 212 696 6000
Washington, D.C.
+1 202 452 7373
Client Alert 21 Apr. 2022
New Laws Targeting Assets of Russian Oligarchs: The U.S. Announces Task Force KleptoCapture and the Kleptocracy Asset Recovery Rewards Program
Client Alert 19 Apr. 2022
U.S. President Biden Expands Export Controls Imposed on Russia and Belarus
Client Alert 14 Apr. 2022
U.S. President Biden Imposes Sixth Tranche of Economic Sanctions Against Russia
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