Compliance og krisehåndtering
Internasjonale sanksjoner og eksportkontroll
2020
US amends North Korean Sanctions Regulations, imposes secondary sanctions
Last week, the US Department of the Treasury's Office of Foreign Assets Control amended the North Korea Sanctions Regulations (31 CFR part 510, "the Regulations"). The revised Regulations implement the Treasury-administered provisions of the North Korea Sanctions and Policy Enhancement Act as amended by Countering America's Adversaries Through Sanctions Act and the National Defense Authorization Act for Fiscal Year 2020. The amendments include certain secondary sanctions, and took effect on 10 April 2020.
Internasjonale sanksjoner og eksportkontroll
2020
US imposes secondary sanctions over Nord Stream 2
US imposes secondary sanctions over the Nord Stream 2 pipeline in Europe, currently under construction led by Russian state company Gazprom. The intention is to stop completion of the pipeline.
Internasjonale sanksjoner og eksportkontroll
2019
US prolongs sanctions on South Sudan for 1 year
On 1 April 2019, President Trump declared that the US sanctions in relation to South Sudan will continue for 1 year
Internasjonale sanksjoner og eksportkontroll
2019
US considers Venezuela secondary sanctions
Previously, we have informed of developments to the US primary sanctions on Venezuela. This week, the US indicated that also secondary sanctions might be on their way.
Internasjonale sanksjoner og eksportkontroll
2019
EU extends sanctions regimes on Egypt and on Bosnia and Herzegovina for 1 year
The EU has extended its sanctions against Egypt for 1 year until 22 March 2020.
Internasjonale sanksjoner og eksportkontroll
2019
US renews legal basis for sanctions against Iran
On 12 March 2019, the US renewed the legal basis for its sanctions against Iran.
Internasjonale sanksjoner og eksportkontroll
2019
US issues updated General License 7A in relation to sanctions against Venezuela
Last week, we informed that OFAC had issued General Licences 3D and 9C relating to certain Venezuelan bonds and Petroleos de Venezuela S.A. ("PdVSA") securities. Yesterday, OFAC issued yet another General Licence relating to US sanctions against Venezuela.
Internasjonale sanksjoner og eksportkontroll
2019
Updated General Licenses in relation to the US Sanctions against Venezuela
Previously, the US President has issued various Executive Orders ("EO"s) to stop the human rights abuses and antidemocratic actions of the regime of Venezuelan President Nicolas Maduro. Various General Licenses, issued by OFAC, do however provide exemptions from the EO provisions in order to minimize the impact on the Venezuelan people and US interests.
Internasjonale sanksjoner og eksportkontroll
2018
EU renews its Russia sectoral sanctions
On 21 December 2018, the EU decided to extend its Russia-related sectoral sanctions and export controls for another six months, until 31 July 2019.
Internasjonale sanksjoner og eksportkontroll
2018
New US sanctions against Nicaragua
On 20 December 2018, President Trump signed into law the Nicaragua Human Rights and Anticorruption Act of 2018. Being quite limited in scope, the Act instructs the US to oppose international loans and financial or technical assistance to the Nicaraguan government for projects in Nicaragua, unless the loans are sought for the purposes of addressing basic human needs or promoting democracy in Nicaragua.
Internasjonale sanksjoner og eksportkontroll
2018
EU lifts Eritrea sanctions
On the 10th of December, the EU terminated its sanctions regime against Eritrea.
Internasjonale sanksjoner og eksportkontroll
2018
Norway lifts Eritrea sanctions
Earlier this month, we informed that the UN has lifted its sanctions against Eritrea after nine years as a consequence of the improved political and military situation in the country.
Internasjonale sanksjoner og eksportkontroll
2018
UN lifts Eritrea sanctions
On 14 November 2018, the UN Security Council adopted resolution 2444 (2018) terminating all UN restrictive measures against Eritrea with immediate effect.
Internasjonale sanksjoner og eksportkontroll
2019
US extends sanctions on Somalia for 1 year
On 10 April 2019, President Trump extended the US sanctions relating to Somalia for 1 year.
Internasjonale sanksjoner og eksportkontroll
2019
EU Council extends sanctions on human rights violations in Iran
This week, the Council of the EU extended its restrictive measures responding to serious human rights violations in Iran.
Internasjonale sanksjoner og eksportkontroll
2019
US prolongs sanctions on South Sudan for 1 year
On 1 April 2019, President Trump declared that the US sanctions in relation to South Sudan will continue for 1 year.
International sanctions and export control
2019
Development in US sanctions relating to Venezuela
On 17 April 2019, OFAC designated Banco Central de Venezuela under Executive Order 13850, as amended, for operating within the Venezuelan economy. At the outset, this means that all dealings involving Banco Central de Venezuela, or entities owned 50 % or more by this bank, are prohibited if subject to US jurisdiction.
Internasjonale sanksjoner og eksportkontroll
2019
Possible future development in EU sanctions relating to Libya
On 11 April 2019, the High Representative of the EU, Federica Mogherini, made statements that, by some, have been interpreted as a possible warning of further EU sanctions relating to Libya.
Internasjonale sanksjoner og eksportkontroll
2019
US will not renew Iran oil exceptions
On 22 April 2019, the US Secretary of State Mike Pompeo announced, somewhat surprisingly, that the US will not renew any of the existing Significant Reduction Exceptions ("SRE"s) that were issued for eight countries on 3 November 2018. The decision aims to "bring Iran’s oil exports to zero", according to the White House, and underscores the US determination to expand and enforce its maximum pressure against Iran.
Internasjonale sanksjoner og eksportkontroll
2019
Significant shift in US extraterritorial sanctions against Cuba. US sanctions and EU regulations go head to head.
On 17 April 2019, the Trump Administration announced that US nationals will be allowed to file lawsuits against any person or company trafficking in Cuban confiscated property, before US courts. This by activating the long-suspended Title III of the Libertad Act. In his reasoning, the Secretary of State remarked that "Sadly, Cuba’s most prominent export these days is not cigars or rum; it’s oppression." The EU views the decision as contrary to international law and will, according to its High Representative, use the EU Blocking Regulation to prohibit EU persons from complying with it.
Internasjonale sanksjoner og eksportkontroll
2019
US warns of potential sanctions relating to INSTEX and of sanctions on Iranian oil
US warns of potential secondary sanctions on INSTEX
Internasjonale sanksjoner og eksportkontroll
2019
Iranian Metal Sanctions Update
• US sanctions now prohibit Norwegian companies and banks from engaging in most transactions in Iran's metal sector. • There are fewer than 60 days left to wind down Iranian metal transactions that began before the sanctions were implemented.
Internasjonale sanksjoner og eksportkontroll
2019
Sanctions update regarding Iran
On 24 June 2019, President Trump announced another set of sanctions targeting Iran.
International sanctions and export control
2019
US threatens secondary sanctions relating to Nord Stream 2
US threatens secondary sanctions over the European Nord Stream 2 pipeline. Foreign parties involved in the construction could be subject to future US sanctions.
Internasjonale sanksjoner og eksportkontroll
2019
Update: US sanctions on Cuba
Multiple lawsuits filed under Libertad Act
Internasjonale sanksjoner og eksportkontroll
2019
Companies Transacting with Chinese Shipowners Face New Sanctions Risks
Last week, the Trump Administration imposed sanctions against Chinese entities and individuals that it has determined have been trading in Iranian oil
Internasjonale sanksjoner og eksportkontroll
2019
New US (and potential EU) sanctions on Turkey
Turkey's military offensive in north-east Syria has led to new US primary and secondary sanctions from the US and announcements of potential future sanctions from the EU.
2018
Ny hvitvaskingslov og -forskrift trer i kraft 15. Oktober 2018
Forskrifter til ny hvitvaskingslov er vedtatt og det er besluttet at nytt regelverk trer i kraft 15. oktober 2018. Med ny hvitvaskingslov og -forskrift vil Norge implementere sentrale deler av EUs fjerde hvitvaskingsdirektiv og anbefalingene fra Financial Action Task Force (FATF).
Internasjonale sanksjoner og eksportkontroll
2019
OFAC announces changes in sanctions rules on Cuba
In previous Sanctions Alerts, we have discussed the Trump administration's shift in its sanctions policy against Cuba. Last week, the Department of the Treasury's Office of Foreign Assets Control (OFAC) took additional steps intended to financially isolate the Cuban government.
2018
Corporate criminal liability; the impact of an effective compliance program
An effective compliance program is essential for any business and it needs to be strong, both on paper and in practice. It addition to providing measures to assist companies to prevent, detect and respond to violations of laws and regulations, such programs have an important role to play as part of any defence against corporate criminal investigations and prosecutions.
Internasjonale sanksjoner og eksportkontroll, Compliance og krisehåndtering
2018
Considerations for Norwegian Companies after the US Withdrawal from the Iran Nuclear Deal
On May 8, President Donald Trump announced that the United States would withdraw from the Iran nuclear deal.
Internasjonale sanksjoner og eksportkontroll, Compliance og krisehåndtering
2018
What Do President Trump's Iran Threats Mean for Norwegian Companies?
At last month's State of the Union address, President Trump called on Congress to "address the fundamental flaws in the terrible Iran nuclear deal". Trump has been attacking the deal, formally known as the Joint Comprehensive Plan of Action (the "JCPOA"), since he began campaigning for the presidency. But this latest statement, made at one of Washington's most important political events and coming on the heels of Trump's January 12 threat to withdraw from the JCPOA, suggests that the president may be closer to taking action. If Trump does decide to end US participation in the JCPOA, how will he do it? And what will this mean for Norwegian companies considering business in Iran?
2018
Should privilege against self-incrimination apply to corporate investigations?
Privilege against self-incrimination is a fundamental principle that protects witnesses from revealing information which might expose them to an accusation or criminal charge. Many legal systems recognise this privilege, and in Norway the right to protect oneself against self-incrimination is a rule of law. The privilege derives both from the right to a fair hearing as defined in article 95 of Constitution and article 6(1) of the European Convention on Human Rights in addition to article 14(3)g of the United Nations Convention on Civil and Political Rights. In the US the privilege is enshrined in the Fifth Amendment to the Constitution.