Takeaways Sanctions operate prospectively and do not affect payment obligations to a non-sanctioned party accruing before sanctions became effective. Payment obligations under standby letters of credit at issue were autonomous and unconnected with the underlying transaction. The fulfilment of an independent obligation owed by a German bank to Irish-incorporated aircraft…
In response to President Putin’s televised recognition of Donetsk and Luhansk People’s Republics (“DNR” and “LNR”) of Ukraine as “independent” nations, and reports of Russian troops being ordered into Ukrainian territory, the United States has imposed Crimea-style comprehensive sanctions on the DNR and LNR prohibiting new U.S. investment as well…
The Treasury Department has placed several prominent Russian individuals and companies on the Specially Designated Nationals and Blocked Persons lists (SDN list). Several of these parties are Russian billionaires previously identified in the Treasury Department’s so-called “Oligarch List” reported to Congress on January 29, 2018. Under the general licenses issued…