Trump Sanctions Policies Still Undefined, But Could Affect Many Nations and Compliance Officers – Part 3: Steven Bannon’s “America First” Agenda Looms As Big Factor

January 31, 2017
By: Anna Sayre, Legal Content Writer, SanctionsAlert.com

In this series, we present the comments and assertions made by President Donald Trump and his top assistants concerning economic sanctions and export controls so compliance professionals can make informed decisions as to the likely positions of the new U.S.administration in the next four years. (more…)

Trump Policies on Economic Sanctions Could Affect Many Countries and U.S. Compliance Officers – Part 2: New Administration Signals New Trade Controls, Sanctions on China

January 17, 2016
By: Anna Sayre, Legal Content Writer

In this second part of the series, we examine Mr.Trump’s comments and stated views on China.

Power of US President ToInfluence Sanctions Policy

The US President has substantial power to enforce, strengthen and waive sanctions with a stroke of a pen. Though sanctions may be authorized by statutes, most sanctions imposed by the Office of Foreign Assets Control (OFAC) arise from the exercise of Presidential national emergency powers through executive orders. The International Emergency Economic Powers Act (IEEPA) grants the President broad authority to respond to “unusual or extraordinary threat” to the national security, foreign policy, or US economy.  The President exercises this authority by officially declaring what he/she believes to be a ‘national emergency’. (more…)

What to Expect for Economic Sanctions Under President Trump?

January 13, 2017
By Anthony Rapa, Alexis Early and Peter Jeydel*

President-elect Trump has made bold and surprising pronouncements about what he may do after January 20 in the field of international affairs, and these foreign policy choices are likely to have a significant impact on the future course of U.S. economic sanctions programs targeting Iran, Cuba, Russia and other areas. Mr. Trump has said he would terminate the Iran nuclear deal, and with it the sanctions rollback that has taken place over the past year, although actually convincing the rest of the world to re-impose sanctions on Iran would be a monumental feat of diplomacy.  On Cuba, Mr. Trump has given reasonably clear signals both that he would support the recent easing of sanctions and that he would reverse it, so the actual policy of the incoming Administration is hardly better than a 50/50 guess at this stage, though with the odds slightly favoring some tightening of sanctions.  Russia may be different.  That is one area in which Mr. Trump’s statements and actions point to a real possibility of a wholesale change in U.S. policy, although bipartisan congressional concerns with Russia may present a major obstacle to radically changing the current state of affairs, at least without significant concessions by Russia. (more…)

Primer on agencies that enforce US sanctions: State agencies and regulators

November 3, 2016
By Anna Sayre, Legal Content Writer, SanctionsAlert.com

The US has one of the most complex national systems of sanctions enforcement in the world. This system derives from the number of agencies that are empowered to initiate actions against violators of US sanctions. Because each US agency maintains a different “Do Not Touch” list, organizations and individuals on the various lists may differ. Furthermore, the regulations issued by these various agencies often have areas of overlap. It is not uncommon for three or four US agencies to take action jointly, thus exposing a business to multiple investigations and varying penalties. (more…)

Sanctions: Brainteasers With Serious Consequences

By: Davina Given*

Failure to comply with financial sanctions carries serious penalties, most notably in the US, where banks have collectively paid billions of dollars in fines.  Even in the UK, a failure to comply with sanctions carries the potential for unlimited criminal and regulatory fines and/or imprisonment.  Yet financial sanctions are often difficult for most businesses to grapple with, particularly if they do not have the resources of the very largest businesses.  Political imperatives may lead to the imposition of financial sanctions in respect of existing, longstanding business.  Individual targets may change quickly and abruptly, with little fanfare.  Different countries involved in a transaction may apply slightly different financial sanctions, so that the transaction may be legal in one country but illegal in another.  Yet on top of those issues, there is a further legal difficulty: what does any particular financial sanction actually prevent? (more…)

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