Alexander Brandt

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OFAC addresses North Korea’s illicit shipping practices with updated advisory document

On Thursday March 21, 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) updated the advisory document it published on February 23 regarding North Korea’s illicit shipping practices. The updated guidance provides further information about North Korea’s deceptive shipping practices aimed at evading international sanctions and provides a list of ‘red … Continue Reading

OFAC imposes strong sanctions on Venezuela’s PDVSA

On Monday January 28, the U.S. Department of Treasury, Office of Foreign Assets Control (OFAC) imposed strong sanctions on Petróleos de Venezuela, S.A. (PdVSA), a major Venezuelan state-owned oil and natural gas company. The U.S. is now prohibited from engaging in transactions with the company, and all property and interests in property of PdVSA that are … Continue Reading

United States fully reimposes secondary sanctions on Iran

On November 5, the United States reimposed the final tranche of sanctions on Iran, which had been lifted pursuant to the Joint Comprehensive Plan of Action (“JCPOA”) in 2016. The vast majority of these sanctions are “secondary sanctions,” being those which target non-U.S. persons and companies even where there is no U.S. nexus (e.g. the … Continue Reading

Iran Sanctions: new developments and how to handle them

On 8 May 2018, President Trump announced that the United States would withdraw from the Joint Comprehensive Plan of Action (JCPOA). In conjunction with that announcement, the President issued a National Security Presidential Memorandum (NSPM) directing the re-imposition of certain secondary sanctions, being those that apply to non-U.S. persons even where there is no U.S. … Continue Reading

Iran sanctions: United States reimposes sanctions and the EU responds

In the early hours of Tuesday, 7 August 2018, and as foreshadowed by President Trump’s announcement on 8 May 2018, the United States reimposed certain secondary sanctions on Iran, being those which apply to non-U.S. persons. The imposition of these sanctions follows the conclusion of a 90-day wind-down period and, as mentioned in our previous … Continue Reading

Iran Sanctions Update: August implementation deadline is approaching, are you ready?

President Trump announced that the United States would withdraw from the Joint Comprehensive Plan of Action (JCPOA) on 8 May 2018. In conjunction with that announcement, the president issued a National Security Presidential Memorandum directing the re-imposition of certain secondary sanctions, being those that apply to non-U.S. persons even where there is no U.S. nexus. … Continue Reading
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