can designate a foreign party (an individual or entity) for sanctions. One of the most controversial parts of the sanctions laws is that the U.S. As a result, they have a direct impact on activities of many U.S. and certain foreign companies including exporters, financial institutions, companies in effectively all industries and even non-profit organizations. parties entering business transactions with targeted countries or individual parties, and blocking assets of targeted parties. They frequently take the form of prohibitions on U.S. Sanctions are typically imposed to force foreign adversaries to change bad behavior – such as developing nuclear weapons or terrorist activity. foreign policy interests around the world. While originally adopted to freeze assets of enemies in times of war, they have evolved into a powerful tool for advancing U.S. Sanctions are typically initiated by the President issuing an Executive Order declaring a national emergency under the International Emergency Economic Powers Act (“IEEPA”), the National Emergencies Act or similar authority and designating the parties targeted for sanctions. Treasury Department, in conjunction with the State Department and other U.S. They are administered by the Office of Foreign Assets Control (“OFAC”) within the U.S. foreign policy and national security goals. sanctions laws are a set of legal requirements designed to achieve U.S. Due to the severe civil and criminal penalties involved (including recent penalties of over $1 billion), it is important for companies and their counsel to understand these laws. While they often appear to affect distant countries such as Iran and N. companies do not understand the significance of these laws. It seems almost every day there are reports of new developments under the U.S.
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