More War by Other Means: Sanctioning the Wife of Syria’s President Makes No Sense to Anyone
More sanctions, by all means. More grief and suffering and more people around the world wondering what exactly the United States is doing.
I am a recipient of regular, usual weekly, emails from the Department of the Treasury providing an “Update to OFAC’s list of Specially Designated Nationals (SDN) and Blocked Persons.” OFAC is the Office of Foreign Assets Control, which is tasked with both identifying and managing the financial punishments meted out to those individuals and groups that have been sanctioned by the United States government. A recent update, on November 10
On December 28, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“
FAQs”) that clarify the scope of Executive Order (“
E.O.”) 13959, the basis for OFAC’s new Chinese Military Companies sanctions program. These FAQs define key terms and clarify how OFAC will interpret E.O. 13959’s prohibition against U.S. investment in the securities of Communist Chinese Military Companies (“
CCMCs”), which goes into effect on January 11, 2021. In general, like previous sanctions programs, the new FAQs show that OFAC will read commonly used terms much more broadly than their common usage might suggest. Now that OFAC has clarified its stance on E.O. 13959, those operating in the investment management sector, especially banks, broker-dealers, investment advisers, and funds should review their assets to determine whether E.O. 13959 could affect their operations. The FAQs represent a Trump Administration decision to continue an aggressive approach toward CCMCs, a
Thursday, December 31, 2020
The United Kingdom (UK) approved its second COVID-19 vaccine this week, while the European Union (EU) moved forward quickly with distribution of its first-approved vaccine to its Member States. United States (US) President Donald Trump signed another COVID relief measure linked to an Omnibus appropriations bill late on Sunday, after objecting initially to a number of provisions and calling for additional congressional action, which has kept the US Congress in Washington this week.
On the eve of Christmas Day, the UK and EU secured a deal outlining terms for the two trading partners after Britain exits the Customs Union on 31 December. This week, the EU also secured a deal with the People’s Republic of China (“China” or “PRC”) that addresses investments. Meanwhile, the US Government unveiled its new Aluminum Import Monitoring and Analysis (AIM) system and released two reports – one focused on human trafficking in the seafood su
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Covid has wreaked havoc on deal numbers and the economy generally, but one light at the end of the tunnel we are all hopefully approaching quickly is that buyers with significant cash reserves will start to buy companies and assets that need to sell as a result of those economic troubles. Some of those buyers will be non-US individuals or entities coming to America to hunt for opportunities, and accordingly a good number of US in-house lawyers who have spent their entire careers doing purely domestic transactions will need to get up to speed on the “international” aspects of the sale of a company or assets that have always been purely domestic.