U.S. Economic Sanctions Update: Key Changes in 2017 & What They Mean for U.S. and Non-U.S. Businesses
U.S. economic sanctions programs received top billing in the news this year, following major changes further restricting trade with Cuba, Russia, North Korea, and Venezuela, including a significant expansion of "secondary sanctions," which target foreign businesses for transactions that have no nexus to the U.S., but conflict with U.S. national security or foreign policy objectives.
This article reviews some of the key developments and their practical significance for U.S. and non-U.S. businesses. To help non-U.S. businesses better understand how and why these U.S. legal developments may affect them, Part II provides a refresher on the principal jurisdictional hooks for application of U.S. sanctions laws. Part III.A reviews the scope and effect of new secondary sanctions on non-U.S. parties for engaging in transactions with North Korea; Part III.B reviews the scope and effect of revisions to sectoral sanctions on Russia and new sectoral sanctions on Venezuela; and Part III.C reviews the scope and effect of two new State Department lists of restricted parties – the Cuba Restricted List of entities associated with the Cuban military, security and intelligence services, and the Section 231 List of entities associated with the Russian defense and intelligence sectors. Because the subject matter is dense, Part IV offers a tabular summary of the changes discussed in this article, and a few of the key compliance steps that companies may wish to take in response to the changes.
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