Last week, this blog reported that the effect of the Russia sanctions was, at least in certain instance, the imposition of sanctions on certain parties not named in the designation lists. This would occur due to OFAC’s rule that treats…
One of the challenges in compliance with the requirement to refrain from doing business with individuals and entities sanctioned under the new Russian sanctions (or any other sanctions program for that matter) is dealing with the so-called 50 percent rule…
The White House issued an executive order this afternoon starting off the expected sanctions on Russia in response to Russia’s invasion of Crimea. As anticipated, these sanctions involve targeted sanctions on certain individuals and entities involved in the invasion of Crimea, including travel…