Webcast – 2014 Mid-Year Sanctions Update

July 30, 2014

​This 90 minute briefing provides an update on the extraordinary events of the first half of 2014 with respect to economic and trade sanctions. The content of this year’s briefing includes United States sanctions administered by the Office of Foreign Assets Control (“OFAC”), as well as European Union and United Kingdom sanctions. In particular, it emphasizes recent developments and emerging issues related to Russia and Iran, as well as other issues which affect in-house counsel, compliance personnel, directors, and other senior executives.

Topics Discussed Include:

Ukraine-Related Developments

  • U.S. Executive Orders and Designations
  • U.S. legislation
  • Key EU and UK sanction regulations on Russia and Ukraine
  • Updates to implementation of EU Russian sanctions in the offshore jurisdictions

Other U.S. Sanctions developments

Executive Orders

  • 13664 Blocking Property of Certain Persons With Respect to South Sudan
  • 13667 Blocking Property of Certain Persons Contributing to the Conflict in the Central African Republic
  • 13668 Ending Immunities Granted to the Development Fund for Iraq

Significant OFAC Regulations

  • Publication of Final Rule amending and reissuing the Syrian Sanctions Regulations

General Licenses

  • Iran General Licenses
  • WMD proliferation

Government Agency Guidance

  • Iran General License D-1 and Related Frequently Asked Questions
  • Frequently Asked Questions on Iran/TSRA General Licenses
  • Updated Frequently Asked Questions Regarding Burma Sanctions
  • Frequently Asked Questions on South Sudan-related Executive Order

Significant Designations

  • Update to Foreign Sanctions Evaders, Kingpin and Syria Lists

Major Enforcement Actions

  • Key OFAC and state enforcement actions

Other E.U. and U.K. Sanctions Developments


  • Updates to key EU and UK sanctions regulations on countries such as Iran, Syria, Central African Republic and Libya
  • Sanctions and Deferred Prosecution Agreements

Case Law

  • Key challenges to inclusion on EU sanctions lists
  • Syria International Islamic Bank v Council [first annulment of Syrian listing]
  • Ahmed Ezz & Ors v Council  [first judgment regarding the EU’s sanctions relating to Egypt]
  • Gary Hyde v R [appeal against 7 year sentence for export controls violations refused]
  • Bank Mellat v HM Treasury [sanctioned Iranian bank suing HMT for $4bn]

EU Member State Enforcement Actions

  • UK’s National Crime Agency investigating company for dealings with Iranian banks
  • Spanish authorities’ prosecution of individuals accused of exporting sensitive missile technology to Iran
  • German authorities prosecute German-Iranian individual accused of exporting goods that could be used in a weapons program

Looking Forward

  • Prospects and details of a comprehensive Iran nuclear deal
  • Prospects of future Ukraine-related sanctions

Who Should View This Program:

In-house counsel, compliance officers, directors, senior executives, finance and audit staff, marketing executives and business development managers responsible for overseas business.

View Slides [PDF]



Judith A. Lee — Judith A. Lee is a partner in the Washington, D.C. office and Chair of the firm’s International Trade Practice Group. Ms. Lee practices in the areas of international trade regulation, including USA Patriot Act compliance, Foreign Corrupt Practices Act, economic sanctions and embargoes, and export controls.

José Fernandez — José W. Fernandez is a corporate partner in the New York office of Gibson, Dunn & Crutcher and Co-Chair of the Firm’s Latin America Practice Group. His practice focuses on mergers and acquisitions and finance in emerging markets in Latin America, the Middle East, Africa and Asia.

Patrick Doris — Patrick Doris is a partner in the Dispute Resolution Group of Gibson Dunn & Crutcher’s London office, where he specializes in commercial litigation, competition law, regulatory disputes and complex investigations.

Ronald Kirk — Ron Kirk is Senior Of Counsel in Gibson, Dunn & Crutcher’s Dallas and Washington, D.C. offices. He is Co-Chair of the International Trade practice and is also a member of the Public Policy, Crisis Management, Mergers and Acquisitions and Private Equity practice groups.

Mark Handley — Mark Handley is an English-qualified Solicitor-Advocate in the London office of Gibson, Dunn & Crutcher.  He is a member of the firm’s Dispute Resolution, International Arbitration and White Collar Defense and Investigations Groups.

Attila Borsos — Attila Borsos is an Associate Attorney based in the Brussels office of Gibson Dunn. Mr. Borsos specializes in EU Competition Law and International Trade.

David Wolber — David A. Wolber is an associate in the New York office of Gibson, Dunn & Crutcher and a member of the Firm’s International Trade and White Collar Defense and Investigations Practice Groups.

Eric Lorber — Eric Lorber is an associate in Gibson Dunn’s Government Contracts, International Trade Regulation and Compliance, and Litigation practices in the firm’s Washington, D.C. Office.  Mr. Lorber advises clients on OFAC administered sanctions and regulations, CFIUS filings, and export control and compliance programs.

Andrea Farr — Staff Attorney in Gibson Dunn’s International Trade Regulation and Compliance Practice. Ms. Farr advises clients regarding OFAC sanctions, export controls and CFIUS matters. She assists clients in the development of sanctions and export control compliance programs and in obtaining and complying with licenses. In addition, Ms. Farr represents clients in international trade-related administrative and appellate proceedings.