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Economic Sanctions & Embargoes

Contacts

Stephan E. Becker
Partner, Washington, DC
T: +1.202.663.8277
Nancy A. Fischer
Partner, Washington, DC
T: +1.202.663.8965
Christopher R. Wall
Partner, Washington, DC
T: +1.202.663.9250
Aaron R. Hutman
Partner, Washington, DC
T: +1.202.663.8341
See All Professionals

Pillsbury helps clients navigate the many novel issues, opportunities and restrictions arising from recent dramatic changes in sanctions policies, including with respect to Iran, Cuba, Venezuela, Russia and Myanmar/Burma.

Pillsbury has deep experience advising clients on compliance with economic embargoes imposed by the U.S. government under the International Economic Emergency Powers Act and the Trading with the Enemy Act, including sanctions regulations administered by the Treasury Department’s Office of Foreign Assets Control (OFAC) with respect to countries such as Iran, Cuba, Venezuela, Russia, Syria, North Korea, Sudan and Myanmar/Burma, as well as Specially Designated Nationals (SDNs). We also conduct internal investigations, prepare voluntary disclosures and represent companies in OFAC enforcement actions, including negotiations of reduced civil penalties for the violation of sanctions regulations.

Representative Experience

  • Advised a U.S.-based international cruise line and its affiliates on U.S. sanctions rules in relation to passengers, employees and operation; obtained licenses related to Crimea sanctions; advised on Cuba sanctions reform.
  • Advised an international media company on entry into Myanmar/Burma market, including coordinating advice from local counsel on structuring, providing strategic advice on sanctions, anti-corruption, banking and AML challenges, and supporting the acquisition of a local Myanmar company.
  • Served as principal international trade counsel for one of the largest petroleum companies, advising on all sanctions and compliance issues, including Iran sanctions developments (CISADA, ITRA, NDAA, etc.), the impact of new Burma sanctions developments on grandfathered investment activity, as well as Sudan, Syria and other sanctions programs.

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  • Construction
    • Advised a client on U.S. state-level sanctions and risks in relation to project work in Iran.
  • Energy
    • Advised a major energy corporation in connection with OFAC’s Venezuela sanctions program, including in-depth engagement with the Treasury and State departments concerning application of various sanctions.
    • Advised a nuclear power company active in Turkey on U.S. and European sanctions relating to Russia.
    • Counseled a Chinese nuclear entity on proposed sanctions implications of acquisitions of uranium mine with partial ownership involving Iran.
    • Assisted a U.S.-based fuel provider with OFAC application to release blocked funds and advised on licensing requirements involving Cuba.
    • Advised a major energy corporation in connection with OFAC’s Russia sectoral sanctions program.
    • Assisted an Asian company and its U.S. affiliate in response to U.S. state-level sanctions targeting activity with Iran (several U.S. states have independent sanctions regimes authorized by U.S. federal statutes).
    • Advised an Asian energy industry company on the impact of sanctions for Iran and Russia for project planning and compliance.
    • Reviewed and advised on sanctions contractual requirements in connection with a credit agreement for a U.S. energy company.
  • Financial
    • Analyzed Russia-related sanctions implications for the Singapore branch of a large Japanese financial institution in connection with activities in support of gasoline contract.
    • Assisted a prominent U.S.-based financial institution in designing its risk-based compliance program covering all areas of its operations, including banking transactions, charge card processing and travel services.
    • Provided advice to foreign banks regarding improving their AML and sanctions compliance programs.
    • Advised the largest bank in EU jurisdiction on sanctions and AML compliance, as well as the banking industry association of that country, including responding to complex Russia sanctions issues and interaction with U.S. Treasury and State Department officials.
    • Advised a European financial institution in sanctions implications in connection with transactions related to Iran.
    • Advised a private equity fund with European portfolio affiliates proposing work with Iran; provided compliance and strategic advice under U.S. and EU sanctions law.
    • Assisted a London-based investment fund with substantial Libya Investment Authority assets in obtaining broad OFAC authorization to conduct normal course of business activities with U.S. counterparties.
    • Advised an investment fund in relation to an investment project in Myanmar/Burma on U.S. sanctions issues and assisted in the preparation of investment documents.
    • Advised a U.S. investor on involvement in a Mongolian company that planned to organize a JV with North Korea’s state energy enterprise for development of oil/gas resources and a refinery in North Korea. Obtained compliance assurance letter to OFAC from government in Pyongyang. Subsequently advised on changes in North Korea sanctions and efforts to unwind investment.
    • Assisted financial institutions, real estate companies and other businesses on the negotiation of contract language addressing compliance with executive orders and sanctions regulations.
    • Advised borrowers and lenders in the tailoring of sanctions language to finance arrangements in light of planned business and compliance concerns.
    • Advised and assisted a major UK financial institution as special counsel in an extensive multi-year internal investigation regarding compliance with Iran sanctions regulations, including funds transfers and trade transactions, ultimately resulting in settlements with federal and state agencies.
    • Advised a credit card company on sanctions, financial transactions and new investment rules for U.S. persons and their affiliates in Myanmar/Burma.
  • Food & Agriculture
    • Advised a major agricultural commodities company on compliance with Cuba and Iran.
    • Advised S. company organizing trade with Iran under general licenses for agricultural and food items.
  • Technology & Information Technology
    • Prepared sanctions policy and conduct training for a startup technology company.
    • Advised a global technology company on system-wide approach to services for sanctioned parties; assessing general licenses and Berman Amendment.
    • Assisted a social media and technology company to engage with OFAC in connection with SDN access and use of free social media accounts.
    • Assisted a global technology company obtain OFAC-specific licenses to provide services to certain SDNs.
    • Advised an international media company in connection with potential field work in embargoed destinations, seeking regulatory guidance and obtaining licensing.
    • Conducted internal investigation on a printer manufacturer and its subsidiaries concerning Iran and Syria transactions, and prepared disclosures to OFAC and the Bank for International Settlements (BIS).
    • Advised a social media and technology company in connection with software exports to embargoed destinations.
  • Manufacturing
    • Counseled a Canadian company on sanctions issues in connection with sales to Russia.
    • Assisted a major international aerospace manufacturer with licenses to ship aircraft and components to sensitive countries and with implementing compliance programs.
    • Provided Iran sanctions compliance advice for an Italian company considering equipment sales to European companies with potential for incorporation in systems for Iranian end users.
    • Assisted a Chinese manufacturer of security products with sanctions-related analysis in connection with imports of North Korean labor.
    • Advised a major manufacturing companies with compliance and licensing issues in connection with proposed exports of products to Cuba.
    • Advised European manufacturers on the impact of the Joint Comprehensive Plan of Action (JCPOA) on U.S. and EU sanctions on Iran.
    • Evaluated whether certain activities may be in violation of U.S. secondary sanctions and risks related to SDN designation.
    • Reviewed and analyzed sanctions issues in connection with potential acquisition of a U.S.-based medical optics company by a publicly traded Japanese corporation.
    • Advised U.S. and foreign companies on the complex interplay between U.S. sanctions and foreign antidote measures that target the extraterritorial application of U.S. laws and regulations, developing compliance strategies, and representing companies in multijurisdictional inquiries and enforcement proceedings.
    • Assisted a global electronics manufacturer in navigating the complex interplay of the OFAC and Export Administration Regulations (EAR) restrictions on Cuba, Iran and other embargoed countries, obtaining licenses for replacement parts, and advised on disclosure and compliance issues related to the use of EAR license exceptions.
    • Assisted a U.S.-based global manufacturer on U.S. sanctions concerning transactions by subsidiary entities.
    • Advised foreign companies doing business in Cuba on potential risks due to the recently implemented Title III of the Helms-Burton Act.
  • Satellites
    • Advised satellite companies on potential formation of Iranian joint venture.
    • Advised satellite companies on new Venezuelan sanctions and implications in connection with pre-existing service arrangement.
  • Telecommunications & Media
    • Advised an international media company regarding compliance with OFAC sectoral sanctions in connection with proposed business venture involving a Russian partner.
    • Advised a multinational telecommunications provider in connection with a DOJ investigation involving sanctioned country and persons.
    • Advised an international media company on its entry into Myanmar/Burma market, including coordinating advice from local counsel on structuring, providing strategic advice on sanctions, anti-corruption, banking and AML challenges, and supporting acquisition of a local Myanmar company.
    • Advised companies on the complexities of payments related to authorized JCPOA transactions.
    • Advised an electronics company on OFAC compliance regarding sales of telecommunications devices to Cuba.
    • Advised major international media companies regarding compliance with OFAC sanctions and exemptions applicable to the distribution of films, news feeds and other media.
    • Advised Asian, European and U.S. multinational satellite companies on new SEC reporting requirements relating to Iran and assisted in the preparation of disclosures.
    • Advised global satellite service providers on OFAC licensing and compliance.
    • Submitted OFAC license application in connection with a proposed journalistic project in Cuba.
  • Travel & Transportation
    • Advised a cruise line on U.S. sanctions rules in relation to passengers, employees and operations.
    • Obtained licenses related to Crimea sanctions. Advised on Cuba sanctions reform.
    • Assisted a cruise line with return of blocked funds and other sanctions matters in connection with travel to embargoed destinations.
    • Conducted extensive internal investigations of major international travel service providers with respect to compliance with Cuba sanctions regulations and extraterritorial conflicts with blocking measures adopted in the EU and various member states, Canada, Mexico and Argentina, and represented these companies in OFAC enforcement proceedings.
    • Obtained licenses to unblock funds, permit shipments and (when required) authorize travel to countries subject to sanctions.
    • Advised travel service providers on compliance with the Cuba travel regulations.
  • Aerospace & Defense
    • Assisted an aerospace company with sanctions-related issues following SDN designation of certain company customers in possession of aircraft.
    • Assisted in obtaining licenses for exports/leases of aircraft to Iran and Cuba.
    • Drafted a compliance manual and advised an aircraft leasing and financing company on compliance with applicable sanctions laws, including sectoral sanctions applicable to long-term financing transactions.
    • Obtained licenses to unblock funds, permit shipments and (when required) authorize travel to countries subject to sanctions.
    • Assisted aerospace, airline and travel companies with understanding the JCPOA changes and navigating the OFAC licensing process for transactions with Iran.
    • Advised European air carriers with compliance and licensing issues in connection with proposed travel services to Iran and Cuba.
    • Advised travel service providers on compliance with the Cuba travel regulations.

Practice Area Highlights

  • Pillsbury’s International Trade practice is nationally ranked by Chambers USA and internationally recognized by Chambers Global for our Export Controls & Economic Sanctions, CFIUS, and Trade Remedies & Trade Policy work.
  • Pillsbury received S. News/Best Lawyers recognition for International Trade & Finance.
  • Recognized in 2024 by The Legal 500 U.S. for the breadth of our International Trade capabilities across three categories: CFIUS; Customs, Export Controls and Economic Sanctions; and Trade Remedies and Trade Policy. Client testimonial hails the Pillsbury International Trade team as “…a well-unified, collaborative team that leverages each other’s knowledge based to demonstrate ‘big picture’ understanding as well as specialized advice within categories of issues.”

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