International sanctions are a major compliance challenge for companies worldwide. The regulatory risks associated with economic sanctions, asset-freezing measures and trade embargoes are not new, but they continue to grow in scope and complexity. Dechert’s lawyers are adept at advising clients as to the commercial implications of the legal intricacies and regulatory demands surrounding sanctions and at developing practical, tailored guidance to comply with these measures.
This page brings together a selection of resources on international sanctions. Please visit regularly for updates and contact a member of our Sanctions Team below for more information.
Key Areas of Concern
The United States, European Union and other countries maintain a variety of economic sanctions laws and regulations that impose restrictions on dealings involving certain countries, entities and individuals. While there is some overlap with respect to these sanctions, the nature of restrictions can vary greatly depending on which laws apply to the activity at issue.
This section highlights the current key areas of concern regarding recent sanctions developments.
Iran
In July 2015, the United States, European Union, Iran and other countries entered into the Joint Comprehensive Plan of Action under which the international community agreed to ease certain sanctions against Iran in exchange for Iran’s commitments to curtail its nuclear program. This agreement was implemented in January 2016, and many international sanctions were suspended at that time. However, many other significant restrictions remain in place – particularly with respect to U.S. measures – and companies exploring business opportunities in Iran must ensure that they do not run afoul of sanctions compliance obligations that continue. Below are select updates prepared by Dechert regarding Iran sanctions:
- District Court Upholds Indictment of Turkish/Iranian Billionaire Charged with Evading US Economic Sanctions against Iran (October 19, 2016)
- Iran Sanctions applicable to EU-based companies (February 19, 2016)
- Implementation Day: Iran Sanctions Eased Today (January 16, 2016)
Russia/Ukraine
Since March 2014, the United States and European Union have maintained certain sanctions targeting specified Russian and Ukrainian individuals and entities in response to perceived improper activities of Russia in the Crimean Peninsula and other regions of Ukraine. These measures primarily include sectoral sanctions restricting transactions in certain equity or debt instruments of designated Russian companies in the financial, energy and defense industries as well as more traditional sanctions prohibiting any transactions with other designated Russian and Ukrainian persons. The sectoral sanctions, in particular, raise novel issues unique to the Russia/Ukraine sanctions regimes. Companies engaging in business with designated Russian/Ukrainian persons, or with the Russian oil industry more broadly, should carefully assess whether U.S. or EU sanctions may restrict their activities. Below are select updates prepared by Dechert regarding Russia/Ukraine sanctions:
- U.S.-Russia Business Climate Likely to Change Under Trump Presidency (Novmeber 23, 2016)
- US Imposes Significant Export Restrictions on Russian Oil and Gas Field (August 13, 2015)
- Additional US Sanctions Imposed on Russian and Ukrainian Persons, But No Significant Escalation (August 3, 2015)
- Russia and Ukraine Sanctions - One Year On (June 26, 2015)
Cuba
The United States has maintained a near-comprehensive embargo against Cuba since 1960 that prohibits U.S. persons and their subsidiaries from engaging in almost all transactions involving Cuba. In recent years under President Barack Obama, the United States has eased certain aspects of these sanctions to permit U.S. persons and their subsidiaries to engage in certain transactions with Cuba, including with respect to Cuba’s telecommunications industry and private sector businesses, as well as travel to the island. Significant restrictions remain in place, however, further complicated by “antidote” or “blocking” measures maintained by Canada and the European Union (among others) that prohibit local companies from complying with certain aspects of the U.S. sanctions against Cuba. Companies considering or actively engaging in business with Cuba should ensure that such activities do not raise issues under U.S. sanctions laws. Below are select updates prepared by Dechert regarding Cuba sanctions:
- U.S. Government Takes Steps to Further Ease Restrictions on Cuba (September 24, 2015)
- U.S. and Cuba Seek to Normalize Relations; U.S. to Ease Certain Restrictions (December 18, 2014)
