Sanctions Round Up: Third Quarter 2014

The third quarter of 2014 was marked by the issuance and then significant expansion of U.S. and E.U. sanctions targeting specific sectors of the Russian economy. These sectoral sanctions complement ongoing efforts by both jurisdictions to identify and designate persons contributing to the ongoing instability in eastern Ukraine. Despite an extension in the deadline for a final agreement on Iran’s nuclear negotiation, the United States continued to enforce certain sanctions targeting Iran. OFAC also issued new guidance on the so-called “50 percent” rule toward the end of the quarter that has the potential to greatly expand the application of all U.S. sanctions programs.

Included in quarter’s sanctions round up is a discussion of:

• The Revised OFAC 50 Percent Rule
• U.S. and E.U. Sectoral Sanctions Targeting Russia
• Additional U.S. Sanctions Targeting Iran
• Sanctions Targeting Ongoing Conflicts in Syria, South Sudan, and the DRC
• Updates to Other U.S. and E.U. Sanctions Programs
• U.S. Enforcement Actions
• U.S. Counterterrorism and Counternarcotics Designations
• Annulment of E.U. Sanctions

View full memo, Sanctions Round Up: Third Quarter 2014