Economic Sanctions
Overview
Crowell & Moring's global economic sanctions team leverages its experience from government, industry, and as outside counsel to provide comprehensive advice on every aspect of compliance with the ever-changing nature of international sanctions regimes on behalf of our multinational clients. With major changes announced recently with respect to sanctions on Russia and the Ukraine, Cuba, Iran, and even Venezuela and more than two dozen overlapping, and occasionally conflicting, current sanctions programs in the United States and the European Union (EU), compliance is an ever-present challenge. Our global sanctions team counsels clients on how to conduct business through these myriad complexities.
Contacts
Insights
Client Alert | 5 min read | 04.03.24
On March 29, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”), issued a “notice and request for information and comment” (“RFI”) seeking comments on the Bank Secrecy Act’s (“BSA”) customer identification program (“CIP”) rule. The CIP rule requires U.S. banks to collect a taxpayer identification number (“TIN”) from a U.S. person before opening a new account for that person. For individuals, this TIN will be a Social Security number (“SSN”).
Publication | 10.27.23
Publication | 10.19.23
Event | 09.28.23 - 09.29.23
Representative Matters
Russia
- Conducted regular due diligence on counter-parties and provided guidance on multi-million dollar transactions undertaken by a multinational manufacturer for use in downstream portions of the Russian oil and gas sector.
- Advised a U.S. based Fortune 50 financial institution on the scope of sectoral restrictions on "debt," "transferable securities," and "money market instruments" under U.S. and EU law.
- Represented, in collaboration with our customs team, a U.S. oil and gas company to seek release of exports to Russia that were improperly detained.
Cuba
- Developed a Cuba-specific compliance program for a U.S. automobile manufacturer seeking to utilize the recently announced sanctions relaxations to conduct Cuba outreach.
- Secured a license for a multinational insurer to provide insurance policies without requiring a Cuba carveout.
- Counseled a European subsidiary of a U.S. company on navigating compliance with both U.S. "secondary" sanctions and EU "blocking" statutes restricting such compliance.
Iran
- Represented a U.S. manufacturer in negotiations with a European joint venture partner regarding disposition of Iran-linked sales.
- Counseled multinational publishing company on sales to Iran under the Informational Materials exemption and Publishing General Licenses.
- Drafted guidance for an EU manufacturer on permissible transactions under the sanctions relaxations under the Joint Plan of Action.
Contacts
Insights
Client Alert | 5 min read | 04.03.24
On March 29, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”), issued a “notice and request for information and comment” (“RFI”) seeking comments on the Bank Secrecy Act’s (“BSA”) customer identification program (“CIP”) rule. The CIP rule requires U.S. banks to collect a taxpayer identification number (“TIN”) from a U.S. person before opening a new account for that person. For individuals, this TIN will be a Social Security number (“SSN”).
Publication | 10.27.23
Publication | 10.19.23
Event | 09.28.23 - 09.29.23
Professionals
Insights
Client Alert | 5 min read | 04.03.24
On March 29, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”), issued a “notice and request for information and comment” (“RFI”) seeking comments on the Bank Secrecy Act’s (“BSA”) customer identification program (“CIP”) rule. The CIP rule requires U.S. banks to collect a taxpayer identification number (“TIN”) from a U.S. person before opening a new account for that person. For individuals, this TIN will be a Social Security number (“SSN”).
Publication | 10.27.23
Publication | 10.19.23
Event | 09.28.23 - 09.29.23