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Sanctions & Embargoes

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The US Treasury Department and the US State Department have announced two new rounds of sanctions against Syria, including the first designations under the recently-enacted Caesar Syria Civilian Protection Act (“Caesar Act”). The first round, announced on June 17, 2020, resulted in the addition of 39 individuals and entities to the List of Specially Designated Nationals and Blocked Persons (“SDN List”) maintained by the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) pursuant Caesar…

On 15 July 2020, the U.S. and Gulf Cooperation Council (“GCC”)-led Terrorist Financing Targeting Center (“TFTC”) designated six targets affiliated with the Islamic State of Iraq and Syria (“ISIS”), including an entity allegedly posing as a charity (and its director) based in Afghanistan that allegedly provided support to ISIS’ branch in that country, ISIS-Khorasan (“ISIS-K”). The entities that were designated are: Al Haram ExchangeTawasul CompanyAl-Khalidi ExchangeNejaat Social Welfare Organization Five of these targets (which includes…

The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) recently designated as Specially Designated Nationals (“SDNs”) a number of entities linked to the Iranian steel, aluminum, and iron sectors that are likely to be of particular interest for companies doing trade in or with the Middle East or financial institutions financing trade and business in the region. This post highlights OFAC’s recent action and outlines some practical considerations.On 25 June 2020, OFAC…

On 19 March 2020, the US Treasury Department’s Office of Foreign Assets Control (OFAC) sanctioned five companies based in the United Arab Emirates (UAE), pursuant to Executive Order 13846 (EO 13846), for their alleged involvement in purchasing hundreds of thousands of metric tons of petroleum products from the National Iranian Oil Company (NIOC) for delivery to the UAE. The following UAE-based companies were added to the US Specially Designated Nationals and Blocked Persons List (SDN List): (1) Alam Althrwa…

In the past year the United Arab Emirates (UAE) has witnessed a number of important developments in the area of compliance and financial crime which will have a significant impact on the risk exposure of companies operating in the UAE for the foreseeable future. Over time, collectively, these changes will have a profound impact on the compliance environment in the UAE, particularly as it relates to financial crimes, and companies can no longer approach compliance issues casually.