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Global Economic Sanctions Year-End Summary 22 January 2020

2019 saw significant economic sanctions developments in the United States and Europe. The United States expanded a number of its sanctions programs and engaged in an unprecedented level of enforcement. In turn, European, Canadian, and other governments have wrestled with ways to protect their citizens and companies from the extra-territorial effect of some U.S. sanctions while also implementing new sanctions of their own. Below are highlights surveying the sanctions landscape in 2019.

1. Highlights of U.S. sanctions risks facing global companies

1.1. Cuba: Title III of the Helms-Burton Act activated

In 1996, the United States enacted the Cuban Liberty and Democratic

Solidarity (Libertad) Act of 1996, also known as the Helms-Burton Act (the

“Act”).1 Among the Act’s more controversial provisions is Title III, which

allows U.S. nationals to sue in U.S. courts any individual or entity who

“traffics”2 in (i.e., uses) property that was confiscated by the Cuban

government on or after 1 January 1959. That provision was immediately

suspended by President Clinton, however, and it remained suspended

throughout successive administrations and was without effect.

But the executive branch changed course in April 2019, when the U.S.

Secretary of State announced that the suspension of Title III would lapse on

2 May 2019. Now that the private right of action is available, companies

around the world with activities in Cuba face the potential for litigation in U.S.

courts by those whose property was confiscated by the Cuban government

between 1959 and 1996. A limited number of plaintiffs have now filed

lawsuits under Title III that will be watched closely by the market and

sanctions practitioners as they work their way through the courts.3

Even when the private right of action was suspended, it was advisable for

companies operating in Cuba to conduct diligence on property involved, and

to proactively reach settlements with potential U.S. claimants when property

1 22 U.S.C. §§ 6021-6091.

2 See 22 U.S.C. § 6023(13)(A) (defining “traffics” broadly).

3 Of note, while there are as many as 6,000 estimated “certified claims” for confiscated property arising

under the Title III private right of action, only 22 lawsuits had been filed in U.S. courts to date.

Contents

Contents 1. Highlights of U.S. sanctions risks facing

global companies 1 2. Other developments in U.S. sanctions 6 3. Other developments in EU sanctions 8 Key contacts 9

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was identified as having been confiscated. The need for careful diligence is

now greater than ever in connection with activities involving Cuban property.

EU Response. In 1996, in response to the Helms-Burton Act, the EU

created the EU Blocking Regulation to protect persons and entities under EU

jurisdiction (“EU Operators”) against the extra-territorial effect of the U.S.

sanctions targeting Cuba as mentioned above. In essence, the EU Blocking

Regulation nullifies the effect in the EU of U.S. court rulings based on these

sanctions and allows EU Operators to recover damages arising therefrom.

Furthermore, the EU Blocking Regulation prohibits EU Operators from

complying with such extra-territorial sanctions.

As the United States continued to suspend the application of Title III of the

Helms-Burton Act, there was no need to enforce the EU Blocking

Regulation. However, further to the full activation of the Helms-Burton Act,

the EU announced that it is now considering actively using the EU Blocking

Regulation in relation to the sanctions targeting Cuba.

It remains to be seen how damages claims pursuant to the Helms-Burton

Act will unfold in the United States in the coming months and how the EU

and its Member States will react to specific enforcement cases.

1.2. Iran: expansion of secondary sanctions

Following its withdrawal from the nuclear deal (the “Joint Comprehensive

Plan of Action” or “JCPOA”4) and reimposition of sanctions on Iran in 2018,

the United States has continued its “maximum pressure” campaign against

Iran. So-called “secondary” sanctions that are designed to target non-U.S.

persons engaged in activities with no U.S. nexus continue to expand.5 For

example, in 2019, the United States announced new secondary sanctions

for any persons who engage in significant dealings involving Iran’s iron,

copper, aluminium, and steel industries.6 The United States also issued only

one round of Significant Reduction Exceptions for certain countries to

purchase Iranian oil, to allow those purchases to wind-down, and has

sanctioned non-U.S. entities that have continued to support Iranian oil

sales.7

4 The JCPOA is a multilateral agreement that was originally concluded between Iran, the United States, the

United Kingdom, France, Germany, Russia, China, and the EU. The agreement aims to stop and prevent

Iran from producing nuclear weapons. In exchange for Iran complying with its commitments under the

JCPOA, the then existing UN sanctions and the most economically damaging nuclear-related sanctions by

the EU and the United States were either lifted or suspended on 16 January 2016.

5 For a high-level discussion on many of these secondary sanctions that the United States imposed

following its withdrawal from the JCPOA, see OFAC’s “Frequently Asked Questions Regarding the Re-

Imposition of Sanctions Pursuant to the May 8, 2018 National Security Memorandum Relating to the Joint

Comprehensive Plan of Action (JCPOA)” (6 August 2018), available at www.treasury.gov/resource-

center/sanctions/Programs/Documents/jcpoa_winddown_faqs.pdf.

6 Executive Order 13871, “Imposing Sanctions With Respect to the Iron, Steel, Aluminium, and Copper

Sectors of Iran” (8 May 2019), available at www.treasury.gov/resource-

center/sanctions/Programs/Documents/13871.pdf.

Notably, on 10 January 2020, the United States sanctioned Iran’s 13 largest steel and iron manufacturers,

including Mobarakeh Steel Company, the biggest steel producer in the Middle East. See U.S. Department

of the Treasury, “Treasury Targets Iran’s Billion Dollar Metals Industry and Senior Regime Officials” (10

January 2020), available at https://home.treasury.gov/news/press-releases/sm870.

7 For example, in September 2019, the United States imposed sanctions under section 3 of Executive

Order 13846 on six Chinese firms, including two subsidiaries of state-owned COSCO Shipping

Corporation Ltd., for knowingly transporting Iranian oil. See Executive Order 13846, “Reimposing Certain

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While a number of sectors in Iran remain sanctions free (for non-U.S.

persons), such as the consumer goods, medical, and agricultural sectors,

the risk of dealings in Iran triggering secondary sanctions continues to rise.8

Diplomatic relations between the United States and Iran continue to decline,

and we do not expect these sanctions to abate in the near future.

Accordingly, non-U.S. companies operating in Iran must remain vigilant to

understand whether their activities may trigger secondary sanctions while

simultaneously observing their sometimes-contradictory obligations under

EU law.

EU’s Position. In response to the toughening of the U.S. sanctions against

Iran, Iran has, amongst others, reduced its commitment to the JCPOA.

Notwithstanding Iran’s violations of the nuclear deal, the EU has continued

the sanctions lifting agreed under the deal. The EU has however demanded

that Iran immediately stop taking steps away from the nuclear deal. On 14

January 2020, the United Kingdom, France and Germany jointly triggered

the dispute resolution mechanism set forth in the JCPOA to hold Iran to

account for its non-compliance. Iran’s continued violations of the nuclear

deal and a further escalation of its conflict with the United States could

culminate in the return of the comprehensive UN and EU sanctions against

Iran that have remained lifted in a matter of weeks, i.e., the so-called

“sanctions snapback”.9

1.3. Russia: maintaining the pressure

Tensions between the United States and Russia remain high, and additional

(albeit limited) sanctions have been imposed with respect to Russia in 2019:

Russian Energy Export Pipelines – In December 2019, the United

States enacted the “Protecting Europe’s Energy Security Act of 2019,”10

which purports to require the President to impose secondary sanctions

against pipe-laying vessels and their owners involved in the construction

of the Nord Stream 2 and TurkStream pipelines, and successor projects.

Those sanctions have not yet been implemented.

Chemical and Biological Weapons (“CBW”) Act – In August 2019,

the United States imposed sanctions on Russia under the CBW Act in

response to Russia’s use of a nerve agent in the United Kingdom in

March 2018. The sanctions prohibit U.S. banks both from participating in

Sanctions With Respect to Iran” (6 August 2018), available at www.treasury.gov/resource-

center/sanctions/Programs/Documents/13846.pdf.

8 Indeed, companies operating even in those sectors must still be mindful of sanctions for transacting with

sanctioned persons or entities, causing violations by U.S. persons including U.S financial institutions, or

other collateral triggers that may not be obvious on the face of their business.

The trend of increasing secondary sanctions continued into 2020 when President Trump issued a new

executive order authorising blocking sanctions on any person that is in, or engages in significant

transactions with or in support of, Iran’s mining, construction, manufacturing, or textiles sectors. For more

information, see Linklaters’ client alert “United States Imposes New Sanctions on Iran’s Construction,

Mining, Manufacturing, and Textile Sectors (10 January 2020), available at

www.linklaters.com/en/insights/publications/us-publications/2020/january/united-states-imposes-new-

sanctions-on-irans-construction-mining-manufacturing-and-textile-sectors.

9 For more information in relation to the sanctions snapback, see Linklaters’ client alert “Could sanctions

against Iran be reintroduced?”, available at www.linklaters.com/en/insights/publications/2019/july/could-

sanctions-against-iran-be-reintroduced.

10 See Title LXXV of the National Defense Authorization Act for the Fiscal Year 2020, available at

www.congress.gov/bill/116th-congress/house-bill/2500/text.

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the primary market for non-ruble denominated bonds issued by Russia

and from lending non-ruble denominated funds to Russia; create a

presumption of denial (subject to exceptions) for license applications

relating to dual-use goods controlled by the Department of Commerce

for chemical and biological weapons proliferation reasons; and require

the United States to oppose loan and financial or technical assistance by

international financial institutions. While the new sanctions could have

been more severe, they allow the administration to demonstrate

compliance with its statutory obligation to impose CBW sanctions.

DASKA – Support exists in Congress for the imposition of additional

sanctions on Russia, and a number of bills were introduced in 2019 to

accomplish that goal. For example, one bill – the Defending American

Security From Kremlin Aggression Act of 2019 (“DASKA”) – would

impose wide-ranging sanctions on Russia for interfering in the 2016 U.S.

presidential election, including by targeting Russia’s energy sector,

banking sector, and its sovereign debt. We cannot predict whether any

particular bill will ultimately be enacted into law, but DASKA has

received considerable attention and bipartisan support in Congress.

1.4. Venezuela: escalation of pressure

OFAC has also sought to place further economic pressure on Venezuela in

2019 in the hopes of driving President Maduro from power. On 5 August

2019, the President issued Executive Order 13884, “blocking” all

Venezuelan government entities and state-owned enterprises. If property in

which any such entity has any interest whatsoever comes into the

possession or control of a U.S. person, it must be “blocked” (frozen), and

U.S. persons are generally prohibited from engaging in transactions with the

entity.11 However, OFAC has issued a range of general licenses to soften

the impact of Executive Order 13884, and the other Executive Orders

targeting Venezuela.

The United States has also been aggressive in imposing secondary

sanctions on non-U.S. companies that engage in significant dealings in the

Venezuelan oil industry or that arguably support the Maduro regime. For

example:

In March 2019, the United States sanctioned Evrofinance Mosnarbank –

which is jointly-owned by Russian and Venezuelan state-owned

companies – for attempting to help the Maduro regime avoid sanctions

against the state-owned oil company Petroleos de Venezuela S.A.12

In April 2019, the United States sanctioned Liberian companies Jennifer

Navigation Ltd., Lima Shipping Corp. and Large Range Ltd., and the

11 Executive Order 13884, “Blocking Property of the Government of Venezuela” (5 August 2019), available at

www.treasury.gov/resource-center/sanctions/Programs/Documents/13884.pdf.

12 U.S. Department of the Treasury, “Treasury Sanctions Russia-based Bank Attempting to Circumvent U.S.

Sanctions on Venezuela” (11 March 2019), available at https://home.treasury.gov/news/press-

releases/sm622.

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Italian shipping company PB Tankers S.P.A. for transporting oil from

Venezuela to Cuba.13

What the United States may have initially intended to be short-term

sanctions meant to help drive Maduro from power have not yet led to regime

change. It remains to be seen what, if any, additional sanctions the United

States may impose to further pressure Maduro to step down.

1.5. EU response to U.S. sanctions programs updates

On principle, the EU opposes secondary sanctions on EU Operators. For

instance, the EU denounced the secondary sanctions in relation to the

construction of the Nord Stream 2 pipeline mentioned above.

The recently elected President of the EU Commission, Ursula von der

Leyen, furthermore announced that she intends to develop proposals to

ensure Europe is more resilient to secondary sanctions. Accordingly, it is

possible that the scope of the EU Blocking Regulation, which currently

already covers a number of U.S. secondary sanctions against Cuba and

Iran, will be expanded to cover other U.S. sanctions with an extra-territorial

effect.14 This means that EU Operators would enjoy protection against an

increased number of U.S. secondary sanctions under the EU Blocking

Regulation. They would, however, at the same time, also be prohibited from

complying with an increased number of U.S. secondary sanctions.

The reality of many EU Operators with global activities is, nevertheless, that

they are strongly connected to the United States, whether in terms of access

to the U.S. market or the U.S. financial system. For these EU Operators a

further expansion of the scope of the EU Blocking Regulation to other U.S.

sanctions programs will add legal complexity and challenges. Furthermore,

the question remains whether the EU Blocking Regulation offers sufficient

protection against the exposure to U.S. secondary sanctions for these EU

Operators.

Another complexity is that the EU Member States are themselves

responsible for the implementation and enforcement of the EU Blocking

Regulation, including for sanctioning possible breaches thereof. The nature

and level of the penalties (e.g., prison term and/or criminal fines, or only

administrative/regulatory penalties) thus vary from EU Member State to EU

Member State, and EU Operators will also need to consider these

differences in implementation and enforcement.

While a number of EU Member States have implemented the EU Blocking

Regulation many years ago, or have recently amended or enacted

implementing legislation, a small number of EU Member States, including

France, still have not implemented any penalties.15 These remaining

Member States may, in light of the EU Commission‘s intention to increase

13 U.S. Department of the Treasury, “Treasury Increases Pressure on Cuba to End Support to Maduro by

Imposing Further Oil Sector Sanctions” (12 April 2019), available at https://home.treasury.gov/news/press-

releases/sm653.

14 For more information, see Linklaters’ client alert “Belgium implements EU Blocking Regulation”, available

at www.linklaters.com/en/insights/publications/2019/may/belgium-implements-eu-blocking-regulation.

15 For more information, see Linklaters’ client alert “Belgium implements EU Blocking Regulation”, available

at www.linklaters.com/en/insights/publications/2019/may/belgium-implements-eu-blocking-regulation.

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the EU’s resilience against secondary sanctions, in the near future be urged

to adopt implementing legislation and issue penalties.

2. Other developments in U.S. sanctions

In addition to the country-specific U.S. sanctions developments detailed

above, 2019 saw significant developments to the U.S. sanctions landscape

more generally.

2.1. Active enforcement by OFAC

There was a marked increase in OFAC enforcement in 2019, with 26 civil

penalties announced, amounting to $1,289,027,059 in penalties and

settlements, compared to seven civil penalties and $71,510,561 in penalties

in all of 2018.16 OFAC’s enforcement actions included a number of firsts last

year. Notably, OFAC brought its first enforcement action based on a

violation of U.S. sectoral sanctions in Russia.17 OFAC also designated third-

country shipping companies (and their vessels) for transporting Venezuelan

and Iranian oil, demonstrating a continued emphasis on sanctions risk in the

shipping18 and petroleum industries as well as a potential sign of increased

use of secondary sanctions authorities.19

2.2. Compliance guidance

Alongside its uptick in enforcement, OFAC published “A Framework for

OFAC Compliance Commitments” (the “Framework”) in May 2019, setting

out not only the five essential components of an effective U.S. sanctions

compliance program, but also helpfully identifying the most prominent “root

causes” of recent sanctions violations.20 The Framework followed months of

focus by OFAC (communicated through its increased enforcement activity)

on the importance of designing, implementing, and maintaining sound

compliance practices. This guidance can serve as a useful blueprint for

global companies considering the sufficiency of their sanctions compliance

programs.21

16 OFAC, Civil Penalties and Enforcement Information, available at www.treasury.gov/resource-

center/sanctions/CivPen/Pages/civpen-index2.aspx.

17 OFAC, Enforcement Information for April 25, 2019, available at www.treasury.gov/resource-

center/sanctions/CivPen/Documents/20190425_haverly.pdf.

18 OFAC has written extensively on the sanctions risks associated with the shipping industry, including in

relation to shipping petroleum and petroleum products to Iran. See, e.g., OFAC Advisory to the Maritime

Petroleum Shipping Community (4 September 2019), available at www.treasury.gov/resource-

center/sanctions/Programs/Documents/iran_advisory_09032019.pdf.

19 OFAC followed those designations in early 2020 by designating a number of Chinese entities under its

secondary sanctions authority for knowingly engaging in significant transactions involving Iran’s metals

sectors under Executive Order 13871. See OFAC announcement, “Treasury Targets Iran’s Billion Dollar

Metals Industry and Senior Regime Officials,” (10 January 2020) available at

https://home.treasury.gov/news/press-releases/sm870.

20 OFAC, A Framework for OFAC Compliance Commitments (2 May 2019), available at

www.treasury.gov/resource-center/sanctions/Documents/framework_ofac_cc.pdf.

21 For more information on the compliance guidance, see Linklaters’ alert “OFAC publishes sanctions

compliance guidance and identifies root causes of violations” (8 May 2019), available at

www.linklaters.com/en/insights/blogs/businesscrimelinks/2019/may/ofac-publishes-sanctions-compliance-

guidance-and-identifies-root-causes-of-violations. For more on how OFAC signals the importance of

compliance through its enforcement activity, see an article published by Linklaters in the International

Financial Law Review, “OFAC provides guidance through enforcement” (26 February 2019), available at

www.iflr.com/Article/3860483/Leading-by-example.html?ArticleId=3860483.

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2.3. Sanctions enforcement by other regulators

In addition to robust enforcement by OFAC, 2019 also saw an increase in

attention to sanctions by other enforcement agencies like the SEC. Notably,

in September 2019, the SEC issued an order settling claims against a U.S.

issuer based on, among other things, its failure to implement adequate

internal accounting controls to prevent bribery and violations of U.S.

sanctions.22 This order is important as it may signal a new trend in using the

SEC’s books-and-records and internal controls provisions as a tool for

enforcement against public companies.

2.4. High diligence and monitoring expectations

OFAC’s enforcement actions in 2019 also serve as a warning to market

participants that it has high expectations when it comes to diligence and

controls. For example:

In one enforcement action, OFAC found that a U.S. company violated

sanctions by leasing aircraft engines to a UAE-based lessee under an

agreement that explicitly prohibited the lessee from using the engines in

relation to any countries subject to U.S. sanctions.23 The UAE lessee

nevertheless installed the engines on a Ukrainian sublessee’s aircraft, which

were in turn leased to the sanctioned Sudan Airways (this was before U.S.

sanctions on Sudan were lifted) and flown to and from Sudan. When the

U.S. company learned how its engines were being used, it immediately

demanded that one outstanding engine be returned and self-reported to

OFAC.

In its announcement OFAC concluded that the U.S. company failed to

“ensure” its engines “were utilized in a manner that complied with OFAC’s

regulations.” OFAC noted, for example, that the company “did not obtain

U.S. law export compliance certificates from lessees and sublessees” and

the company “did not periodically monitor or otherwise verify its lessee’s and

sublessee’s adherence to the lease provision requiring compliance with U.S.

sanctions during the life of the lease.”

This action serves as a helpful reminder of the strict-liability nature of

sanctions violations for U.S. persons and that the inclusion of appropriate

provisions in agreements with counterparties is only one step towards an

effective compliance program.

22 SEC Press Release, “SEC Charges Marketing and Printing Services Provider with FCPA Violations” (26

September 2019), available at www.sec.gov/news/press-release/2019-193.

23 OFAC, Enforcement Information for November 7, 2019, available at www.treasury.gov/resource-

center/sanctions/CivPen/Documents/20191107_apollo.pdf.

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3. Other developments in EU sanctions

In the course of 2019, the EU adopted three new sanctions programs:

3.1. Sanctions against cyber-attacks

This new sanctions program (Council Regulation 2019/79624) establishes a

framework which allows the EU to impose restrictive measures to deter and

respond to (attempted) cyber-attacks which constitute an external threat to

the EU or its member states, including cyber-attacks against third states or

international organisations. The sanctions target persons or entities directly

or indirectly responsible for (attempted) cyber-attacks or having financed or

assisted with such cyber-attacks. These persons or entities do not need to

be linked to one or another country.

Potential sanctions include a travel ban and the freezing of funds and

economic resources of the persons or entities listed under the sanctions

program. EU persons and entities are also prohibited from making funds

available to these sanctioned persons or entities.

3.2. Sanctions against Nicaragua

This new sanctions program (Council Regulation 2019/171625) allows for

sanctions to be imposed on persons and entities responsible for human

rights violations or abuses or for the repression of civil society and

democratic opposition in Nicaragua, as well as persons and entities whose

actions, policies or activities otherwise undermine democracy and the rule of

law in Nicaragua.

Potential sanctions include a travel ban and the freezing of funds and

economic resources of the persons or entities listed under the sanctions

program. EU persons and entities are also prohibited from making funds

available to these sanctioned persons or entities.

3.3. Sanctions against Turkey

These sanctions (Council Regulation 2019/189026) are the consequence of

Turkey’s drilling activities in relation to hydrocarbon exploration, production

and extraction, which have not been authorised by the Republic of Cyprus.

The new sanctions program establishes a framework that makes it possible

to sanction persons or entities responsible for or involved in these

unauthorised drilling activities.

Potential sanctions include a travel ban and the freezing of funds and

economic resources of the persons or entities listed under the sanctions

program. EU persons and entities are also prohibited from making funds

available to these sanctioned persons or entities.

24 Council Regulation (EU) 2019/796 of 17 May 2019 concerning restrictive measures against cyber-attacks

threatening the Union or its Member States, available at https://eur-lex.europa.eu/legal-

content/EN/TXT/?uri=uriserv:OJ.LI.2019.129.01.0001.01.ENG&toc=OJ:L:2019:129I:TOC.

25 Council Regulation (EU) 2019/1716 of 14 October 2019 concerning restrictive measures in view of the

situation in Nicaragua, available at https://eur-lex.europa.eu/legal-

content/EN/TXT/?uri=uriserv:OJ.L_.2019.262.01.0001.01.ENG.

26 Council Regulation (EU) 2019/1890 of 11 November 2019 concerning restrictive measures in view of

Turkey’s unauthorised drilling activities in the Eastern Mediterranean, available at https://eur-

lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.L_.2019.291.01.0003.01.ENG.

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No persons or entities have yet been sanctioned under these new sanctions

programs. Hence, it remains to be seen whether sanctions will be effectively

imposed.

Key contacts

Doug Davison

Partner, Washington, D.C.

Tel: +1 2026549244

Mob:+1 3015293623 doug.davison@linklaters.com

Sean Solomon

Senior U.S. Associate, Washington, D.C.

Tel: +1 2026549260

Mob: +1 2023405616 sean.solomon@linklaters.com

Sterling Darling

Senior U.S. Associate, Washington, D.C.

Tel: +1 2026549219 sterling.darling@linklaters.com

Françoise Lefèvre

Partner, Brussels

Tel: +32 25019415

Mob: +32 475521144 francoise.lefevre@linklaters.com

Michael Lamson

Counsel, Hong Kong

Tel: +852 29015535

Mob: +852 51916265 michael.lamson@linklaters.com

Stefaan Loosveld

Partner, Brussels

Tel: +32 25019521

Mob: +32 478980944 stefaan.loosveld@linklaters.com

Xavier Taton

Partner, Brussels

Tel: +32 25019472

Mob: +32 477773338 xavier.taton@linklaters.com

Liesbeth Truyens

Managing Associate, Brussels

Tel: +32 25019471

Mob: +32 497265888 liesbeth.truyens@linklaters.com

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