Over the last few weeks, the U.S. House and Senate have separately passed a number of amendments to the National Defense Authorization Act for Fiscal Year 2020 (the “NDAA”) that, if enacted, would expand sanctions on persons and activities related to North Korea, China, Russia, Burma, and certain Central American states.
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Samuel H. Chang
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Sanctions Tighten on Iranian Metals Sectors
By Paul Marquardt & Samuel H. Chang on
On May 8, 2019, President Trump issued a new Executive Order expanding secondary sanctions against the iron, steel, aluminum, and copper sectors of Iran. The Executive Order provides authority to impose sanctions on foreign persons who operate in the covered metals sectors or who facilitate significant transactions in connection with those sectors. Unlike direct sanctions (which have long prohibited unlicensed dealings with Iran with a connection to U.S. jurisdiction), secondary sanctions threaten the imposition of sanctions against non-U.S. persons acting entirely outside U.S. jurisdiction. Although the order is immediately effective, firms are permitted 90 days to wind down existing transactions pursuant to an accompanying OFAC FAQ.
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Russia Sanctions Bill Reintroduced by Bipartisan Group of Senators
By Paul Marquardt & Samuel H. Chang on
On February 13, 2019, a bipartisan group of senators introduced a draft bill that, if adopted, would significantly strengthen sanctions relating to the Russian Federation. Introduced as the “Defending American Security from Kremlin Aggression Act of 2019” (“DASKA”), the wide-ranging bill covers a number of subjects, in particular a range of new cybersecurity provisions. This note focuses on the sanctions provisions, which would:
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OFAC Lists Digital Currency Addresses for First Time, Releases New Guidance
By Paul Marquardt, Katherine Mooney Carroll, Alexis Collins, Chinyelu Lee & Samuel H. Chang on
On November 28, 2018, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) identified for the first time digital currency addresses associated with sanctioned persons. The newly sanctioned individuals, Iran-based Ali Khorashadizadeh and Mohammad Ghorbaniyan, were accused of converting digital currency payments into Iranian rial as part of a widespread ransomware scheme. Since 2015, the ransomware scheme (known as “SamSam”) has infected the data networks of corporations, hospitals, universities, and government agencies. According to OFAC’s announcement, the identified bitcoin addresses were used with over 40 digital currency exchangers to process more than 7,000 illicit transactions in bitcoins worth millions of U.S. dollars.
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