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Trade Sanctions

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Following the successful launch of our inaugural virtual Annual Compliance Conference in 2020, we will return this year in a virtual format to deliver our cutting-edge insights and guidance on key global compliance issues, as businesses and enforcement agencies transition to a new post-pandemic global compliance and investigations landscape across five weeks from 6 September – 8 October. Our global experts will be providing practical insights and analysis on significant developments across: anti-bribery and corruption;…

On 7 July 2021, the Swiss government amended the list of designated parties in its Ordinance of Measures against Belarus, targeting an additional 78 individuals and 7 entities. These designated parties are subject to asset freezes, travel bans and a prohibition on funds and economic resources being made available to them or parties owned or controlled by them. These designations follow the coordinated round of sanctions announced by the EU, UK, US and Canada on 21 June 2021…

Following coordinated designations of certain Belarusian individuals and entities earlier this week (see our previous post here), the EU has announced that further sector-based economic sanctions will come into force on 25 June 2021. The restrictions are implemented by Council Regulation (EU) 2021/1030 (the “Regulation“), which amends Regulation (EC) No 765/2006. The new sanctions target a broad range of technology and software, dual-use goods and technology, tobacco, petroleum and potash products, and financial services. The prohibitions apply regardless of…

On June 17, 2021, the US Treasury Department’s Office of Foreign Assets Control (OFAC) issued three pandemic-related general licenses (“GLs“) authorizing certain transactions and activities through June 16, 2022, involving Syria, Venezuela, Iran, or certain blocked entities in these countries. The new GLs are Syria General License No. 21, Venezuela General License No. 39, and Iran General License N,  and they authorize certain transactions and activities related to the prevention, diagnosis, or treatment of COVID-19 (including research or…

Effective June 21, 2021, the Government of Canada imposed new sanctions against 17 individuals and 5 entities under the Special Economic Measures (Belarus) Regulations (the “Regulations”). The sanctions were imposed in response to alleged systemic human rights violations and the May 23, 2021 diversion, by the Belarusian regime, of Ryanair Flight 4978 from its planned course in order to land in Minsk. The imposition of sanctions by the Government of Canada was taken in coordination with the…

On 21 June 2021, the UK and EU both announced further sanctions targeting individuals and entities linked to Myanmar’s military regime. The EU announced that it was imposing sanctions against an additional 8 individuals, 3 economic entities (Myanmar Gems Enterprise; Myanmar Timber Enterprise (“MTE“); and Forest Products Joint Venture Corporation Limited) and the War Veterans Organisation. All designated persons are subject to asset freezes, with individuals subject to travel bans. EU persons are prohibited from making funds…

On 21 June 2021, the EU and UK announced coordinated sanctions against specified Belarusian individuals and entities. This follows the forced landing of a commercial aircraft in Belarus and subsequent detention of a Belarusian journalist, and suggests that the UK is continuing to align its sanctions regime with key allies following Brexit. The sanctions were further coordinated with the US and Canada. The designated parties will be subject to asset freezes, whilst individuals will be subject to…

On June 9, 2021, the Biden Administration issued Executive Order 14034, “Protecting Americans’ Sensitive Data from Foreign Adversaries” (“EO 14034”). EO 14034 revokes three executive orders issued by the Trump Administration that effectively banned certain Chinese connected software applications (“apps”) from operating in the United States. Although EO 14034 revokes these legal authorities and calls for their implementing rules to be rescinded, EO 14034 signals that the Biden Administration will continue to analyze the national security risks presented…

On June 3, 2021, President Biden issued Executive Order 14032, “Addressing the Threat from Securities Investments that Finance Certain Companies of the People’s Republic of China” (the “CMIC EO”). This amends and replaces Executive Order 13959 (EO 13959) and revokes Executive Order 13974 (EO 13974) that restricted investments in certain “Communist Chinese Military Companies” (CCMCs). The main changes implemented by the CMIC EO and related public guidance are to (1) change the group of targeted Chinese companies to focus on…

On May 28, 2021, the Biden Administration issued a press release confirming the re-imposition of sanctions on certain Belarusian state-owned enterprises (SOEs) (presaged by the issuance of wind down Belarus General License 2H on April 19, 2021) and suspending the application of the 2019 US-Belarus Air Services Agreement (“2019 USB Agreement”) in response to the Belarusian government’s apparent forced diversion of a commercial flight to Minsk on May 23. The Press Release also indicates additional sanctions targeting Belarusian government…