Insights

As they have on each previous anniversary, the EU and UK released new sanctions against Russia on February 24, 2025, to mark the three-year anniversary of Russia’s full-scale invasion of Ukraine. For the first time, the United States did not do the same, electing to issue a limited set of Iran-related sanctions on the anniversary instead. The EU package was more fulsome than the UK package, including new port and airport restrictions, additional trade restrictions (including an aluminium ban), enhanced military end-user restrictions, and additional asset freezes and vessel designations.

On February 4, 2025, President Trump issued a National Security Presidential Memorandum (NSPM-2) on “Imposing Maximum Pressure on the Government of the Islamic Republic of Iran, Denying Iran All Paths to a Nuclear Weapon, and Countering Iran’s Malign Influence.” NSPM-2 directs U.S. government agencies to take a range of measures to reimpose “maximum pressure” sanctions on Iran. 

On November 13, 2024, the U.S. Department of the Treasury’s (“Treasury’s”) Office of Foreign Assets Control (“OFAC”) updated its FAQs for insurers in a long-awaited move to modernize its published sanctions compliance guidance for the insurance industry.  None of the industry-specific FAQs had been updated since January 2015, and many had not been amended in more than 20 years, so these updates represent an important step by OFAC to ensure that its public guidance reflects the industry as it is today. 

The United States maintains a complex system of controls over the export of U.S.-origin goods, services, software and technology, which create challenges and heighten compliance risks for companies with global business models.

As regulators on both sides of the Atlantic increase their focus on sanctions and export control evasion, their attention has often turned to the financial services industry.  Join a panel discussion with Crowell, Kharon, and Bank of America regarding these expectations and how to integrate them with the information and tools to which banks realistically have access in today’s global banking ecosystem.  

Join Crowell's Michelle Linderman and Dj Wolff on December 14, 2022, 13:00 UTC for a BIMCO 15 + 15 webinar (15 min presentation, followed by a 15 min Q&A). They will talk about the price cap on Russian oil exports, whereby the G7, along with the European Union and Australia, have agreed to implement a price cap on Russian oil and oil products in order to reduce Russia’s revenues which are funding its war efforts in Ukraine while seeking to ensure energy security.  The price cap is designed to allow companies to provide shipment and insurance of Russian oil and oil products provided that the purchase price is below the agreed price cap, but how has it begun to work in practice, and what are the practical issues being experienced by the different actors in the supply chain?

Please join us for a discussion to explore key issues in the business community as the war in Ukraine continues to reverberate through the global supply chain.

Erik is returning to Crowell after serving as the Deputy Assistant Secretary for the Division for Counter Threat Finance and Sanctions, Bureau of Economic and Business Affairs, U.S. Department of State. This episode discusses Erik's experience at Department of State and how that informs his practice at Crowell, and his thoughts on possible developments under the new Administration. Global Trade Talks is a podcast that shares brief perspectives on key global issues on international trade, current events, business, law, and public policy as they impact our lives.

Global Trade Talks is a podcast that shares brief perspectives on key global issues on international trade, current events, business, law, and public policy as they impact our lives. In this session, hosts and International Trade Practice Leaders Nicole Simonian and Dj Wolff talk with Crowell lawyers David Stepp and Simeon Yerokun about Uyghur Forced Labor law and its recent application to the auto industry.

Global Trade Talks is a podcast that shares brief perspectives on key global issues on international trade, current events, business, law, and public policy as they impact our lives. In this session, hosts and International Trade Practice Leaders Nicole Simonian and Dj Wolff talk with Crowell lawyers Jeremy Iloulian and Laurel Saito about the significant new sanctions and export control authorities included in the recently enacted National Security Supplemental fiscal package. While this legislation is best known for providing U.S. foreign aid commitments for Ukraine, Israel, and Taiwan, it also contains critical trade related provisions that (i) expand the statute of limitations for U.S. sanctions violations; (ii) give the President new authorities to coordinate sanction efforts with the US and UK; (iii) expand sanctions and export controls on Iran (with some targeting Chinese financial institutions); and (iv) provide for new sanctions authorities targeting terror groups.