![]() ![]() Sanctions are typically initiated by the President issuing an Executive Order declaring a national emergency under the International Emergency Economic Powers Act (“IEEPA”), the National Emergencies Act or similar authority and designating parties who will be the target of the sanctions. ![]() Department of the Treasury in Washington, DC, in conjunction with the State Department and other U.S. They are administered by the Office of Foreign Assets Control (“OFAC”) within the U.S. sanctions laws are a complex web of legal requirements designed to achieve the foreign policy goals of the United States. companies and steps they can take to reduce these risks.ġ. The following provides a more detailed discussion of the U.S. ![]() These laws create a growing legal risk for foreign companies and financial institutions – often without their even knowing it. Problems can come out of nowhere – such as when Huawei Technologies CFO Meng Wanzhou was recently arrested in a Canadian airport lounge for extradition to the U.S. List of Specially Designated Nationals and Blocked Persons or other restricted party lists. In addition, foreign persons and entities can be individually designated for sanctions and placed on U.S. sanctions laws can apply to foreign parties in a number of ways - if foreign companies have certain requisite contacts with the U.S., under “secondary sanctions” and for providing material support and assistance to certain parties that have been targeted for sanctions. sanctions violations, including $8.9 billion for financial institutions and $1.19 billion for non-financial companies, every non-U.S. In light of the significant recent penalties imposed on non-U.S. Government can extend the long arm of its jurisdiction around the world - yet the incidence of U.S. parties in certain cases, even in activities that have no connection to the U.S. These laws impose restrictions on entering business transactions with certain targeted countries, companies and even individual persons anywhere in the world. International companies are signaling growing concern about the U.S. The remainder of this article is available in Part II here. Sanctions Laws: Dangers Ahead For Foreign Companies (Part I) By: ![]()
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