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IN 2016 JACK LEW, America’s then treasury secretary, reflected on how his country had, over decades, “refined our capacity to apply sanctions effectively”. But he also gave a warning: overuse “could undermine our leadership position within the global economy, and the effectiveness of our sanctions themselves”.
If the message was “proceed with caution”, it was lost on Donald Trump, who became president soon after. The screw was turned against China, Iran, Russia, Venezuela and others. The steady increase in sanctions “proved to be a rare constant” on Mr Trump’s watch, says Adam M. Smith of Gibson Dunn, a law firm. During Mr Trump’s four years in office, the Office of Foreign Assets Control (OFAC), which oversees American sanctions programmes, targeted roughly twice as many entities and individuals a year as it had during the two-term presidencies of George W. Bush and Barack Obama (see chart).
Biden Administration to Review Possible Sanctions Relief in Response to Covid-19
01/22/2021 | 05:50pm EDT
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By Mengqi Sun The Biden administration is expected to review existing economic sanctions for possible relief to help with the global response in combating the coronavirus pandemic. The secretaries of the State, Treasury and Commerce departments, in consultation with the Health and Human Services secretary and U.S. Agency for International Development administrator, will review existing U.S. and multilateral sanctions to evaluate whether they are hindering responses to the pandemic, according to a provision in a national security directive issued by President Biden on Thursday.
Recovering from a relatively slow start to the year, due in no small part to the global pandemic, the U.S. Foreign Corrupt Practices Act (“FCPA”) Units of the U.S. Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) closed the year with a bang. With 32 combined FCPA enforcement actions, 51 total cases including ancillary enforcement, and a record-setting $2.78 billion in corporate fines and penalties (plus billions more collected by foreign regulators), 2020 marks another robust year in the annals of FCPA enforcement.
This client update provides an overview of the FCPA and other domestic and international anti-corruption enforcement, litigation, and policy developments from 2020, as well as the trends we see from this activity. We at Gibson Dunn are privileged to help our clients navigate these challenges daily and are honored again to have been ranked Number 1 in the
December 18, 2020
On December 14, 2020, the United States imposed sanctions on the Republic of Turkey’s Presidency of Defense Industries (“SSB”), the country’s defense procurement agency, and four senior officials at the agency, for knowingly engaging in a “significant transaction” with Rosoboronexport (“ROE”), Russia’s main arms export entity, in procuring the S-400 surface-to-air missile system. These measures were a long-time coming under Section 231 of the Countering America’s Adversaries Through Sanctions Act (“CAATSA”) of 2017, the President has been
required to impose sanctions on any person determined to have knowingly “engage[d] in a significant transaction with a person that is part of, or operates for or on behalf of, the defense or intelligence sectors of the Government of the Russian Federation.” This includes ROE, and Turkey’s multi-billion dollar S-400 transaction with ROE has been public knowledge for at least three years. Indeed, in