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Much Ado About Sanctions in the United States

The Countering America’s Adversaries Through Sanctions Act (the CAATS Act) of August 2, 2017 impacts sanctions related to Russia, Iran and North Korea.  Key among the changes is that it takes discretion out of the hands of the U.S. President to lift or change certain existing sanctions, particularly the sectoral sanctions imposed against Russia. 

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US Leaves JCPOA Intact But Is Still Ratcheting Up Sanctions Against Iran

When the United States lifted its nuclear-related sanctions as part of its Implementation of the Joint Comprehensive Plan of Action (JCPOA) in January 2016, it left in place several other sanctions mechanisms that could be implemented against Iran. On February 3, following Iran’s tests of certain ballistic missiles, the United States designated twenty-five (25) additional individuals and entities as Specially Designated…

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The Wait is Almost Over: What Will Happen with US Sanctions under the Incoming Trump Administration

Based on comments made by President-Elect Trump during his campaign, we have some indications about the positions his administration may take regarding certain US sanctions programs. By Susan Kovarovics, 11 November 2016

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US Visa Waiver Program: Considerations for Non-US Persons Traveling to the United States

In the wake of eased sanctions against Iran, companies operating in Europe may wish to take advantage of new opportunities involving Iran, including having employees travel to Iran to explore such opportunities. However, having employees engage in such travel gives rise to considerations under the US Visa Waiver Program should the employee subsequently travel to the United States. By Megan…

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EU renews its economic sanctions against Russia, despite growing opposition

On 1 July 2016, the EU Council renewed the economic sanctions targeting specific sectors of the Russian economy, until 31 January 2017. The so-called “phase 3 sanctions”, which were adopted on 31 July 2014 and due to expire on 31 July 2016, specifically target Russia’s financial sector, by limiting the access to capital markets of its major financial institutions. The…

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Do US Changes Regarding Cuba Create Opportunities for Your Business?

Given that the EU has adopted blocking legislation that makes it illegal for persons resident in the EU to refuse business opportunities based on the US embargo against Cuba, some might wonder why I am writing about the US embargo of Cuba. Well, for a change, I am writing about possible opportunities to engage US business partners in your Cuban…

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Despite Iran sanctions relief, limitations remain on non- US companies owned or controlled by US persons

Much attention has been paid as of late to the sanctions relief granted to Iran arising out of the Joint Comprehensive Plan of Action (JCPOA) among the United States and its partners in the P5 + 1 (China, France, Germany, Russia, and the United Kingdom). Although US sanctions relief remains limited, General License H authorizes non-US subsidiaries of US companies…

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What about the banks – are we seeing the first signs of genuine business with Iran?

There is growing frustration in Iran and Europe about the slow pace of reconnecting Tehran to the global financial system. This even led to a recent joint statement by the P5 +1 nations that negotiated the JCPOA explicitly underlining that they will not “stand in the way of permitted business activity with Iran, and will not stand in the way…

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