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Jul 08, 2014

Sanctions Round-Up: Second Quarter 2014

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The headline for the second quarter is, of course, the United States’ enforcement action against Bank BNP Paribas and its breathtaking penalty of $8.9 billion, tied to the allegedly intentional evasion of the US sanctions programs for Sudan and, to a lesser extent, Iran and Cuba. This settlement capped off a series of enforcement actions by US authorities against a variety of actors stemming from violations of all sizes.

Otherwise, most of the action in the past quarter involved the increasingly tense situation in Ukraine, with the United States and Europe implementing targeted and escalated sanctions against actors in Russia and Ukraine in response to ongoing aggression by separatists in the region. As this quarter drew to a close, both the United States and European Union were reportedly threatening sector-based sanctions. With respect to other sanctions programs, the quarter was largely marked by what has come to be viewed as routine activity, with the United States continuing to make limited designations under sanctions targeting Iran’s proliferation of nuclear weapons, foreign terrorist organization operations, and international narcotics traffickers.

View full memo, Sanctions Round-Up: Second Quarter 2014

Authors and Contributors

Philip Urofsky

Partner

Litigation

+1 202 508 8060

+1 202 508 8060

Washington DC

Danforth Newcomb

Of Counsel

Litigation

+1 212 848 4184

+1 212 848 4184

New York

Stephen Fishbein

Partner

Litigation

+1 212 848 4424

+1 212 848 4424

New York

Brian G. Burke

Partner

Litigation

+1 212 848 7140

+1 212 848 7140

New York

Christopher L. LaVigne

Partner

Litigation

+1 212 848 4432

+1 212 848 4432

New York

Barnabas Reynolds

Partner

Financial Institutions Advisory & Financial Regulatory

+44 20 7655 5528

+44 20 7655 5528

London