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
Partner
He/Him/His
- Washington, D.C.
- D | +1.202.624.2500
- Washington, D.C. (CGA)
- D | +1.202.624.2548
- Boston
- D | +1.781.795.4700
Insights
Client Alert | 8 min read | 10.01.25
On September 29, 2025, the U.S. Department of Commerce Bureau of Industry and Security (BIS) announced a sweeping Interim Final Rule (IFR), (the “Affiliates Rule”) expanding which entities qualify as Entity List or Military End-User entities, thereby subjecting those entities to elevated export control restrictions under the Export Administration Regulations (EAR). U.S. export restrictions applicable to entities on the Entity List, Military End-User (MEU) List, and Specially Designated Nationals and Blocked Persons (SDN List) now apply to foreign affiliates that are, in the aggregate, owned 50% or more by one or more of the aforementioned entities. An entity that becomes subject to these restrictions because of its ownership structure will be subject to the most restrictive controls that attach to any of its parent entities, regardless of ownership stakes.
Client Alert | 7 min read | 09.23.25
Client Alert | 9 min read | 09.22.25
From Deepfakes to Sanctions Violations: The Rise of North Korean Remote IT Worker Schemes
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
Partner
He/Him/His
- Washington, D.C.
- D | +1.202.624.2500
- Washington, D.C. (CGA)
- D | +1.202.624.2548
- Boston
- D | +1.781.795.4700
Insights
Client Alert | 8 min read | 10.01.25
On September 29, 2025, the U.S. Department of Commerce Bureau of Industry and Security (BIS) announced a sweeping Interim Final Rule (IFR), (the “Affiliates Rule”) expanding which entities qualify as Entity List or Military End-User entities, thereby subjecting those entities to elevated export control restrictions under the Export Administration Regulations (EAR). U.S. export restrictions applicable to entities on the Entity List, Military End-User (MEU) List, and Specially Designated Nationals and Blocked Persons (SDN List) now apply to foreign affiliates that are, in the aggregate, owned 50% or more by one or more of the aforementioned entities. An entity that becomes subject to these restrictions because of its ownership structure will be subject to the most restrictive controls that attach to any of its parent entities, regardless of ownership stakes.
Client Alert | 7 min read | 09.23.25
Client Alert | 9 min read | 09.22.25
From Deepfakes to Sanctions Violations: The Rise of North Korean Remote IT Worker Schemes
Insights
Sanctions Compliance as a Competitive Advantage in 2018 - The Challenge and Opportunity of Increasing Complexity
|12.26.17
WorldECR, Issue 65
From Deepfakes to Sanctions Violations: The Rise of North Korean Remote IT Worker Schemes
|09.22.25
Trade Consultant Fears Australian Industry 'Not Ready' for AUKUS Exemptions
|05.15.24
Export Compliance Daily
Speed, Complexity of Russia Sanctions Regime Unprecedented, Lawyers Say
|03.03.22
Export Compliance Daily
American Conference Institute's 10th Advanced Forum on Import Compliance & Enforcement
|01.21.16 - 01.22.16
Sanctions/Export Highlights [As of October 24, 2022]
|10.24.22
Crowell & Moring’s International Trade Law
Professionals
Insights
Client Alert | 8 min read | 10.01.25
On September 29, 2025, the U.S. Department of Commerce Bureau of Industry and Security (BIS) announced a sweeping Interim Final Rule (IFR), (the “Affiliates Rule”) expanding which entities qualify as Entity List or Military End-User entities, thereby subjecting those entities to elevated export control restrictions under the Export Administration Regulations (EAR). U.S. export restrictions applicable to entities on the Entity List, Military End-User (MEU) List, and Specially Designated Nationals and Blocked Persons (SDN List) now apply to foreign affiliates that are, in the aggregate, owned 50% or more by one or more of the aforementioned entities. An entity that becomes subject to these restrictions because of its ownership structure will be subject to the most restrictive controls that attach to any of its parent entities, regardless of ownership stakes.
Client Alert | 7 min read | 09.23.25
Client Alert | 9 min read | 09.22.25
From Deepfakes to Sanctions Violations: The Rise of North Korean Remote IT Worker Schemes