The U.S. has intensified its response to Russia's actions in Crimea through additional sanctions passed by Congress and issued by President Obama. The House passed legislation authorizing sanctions on those responsible for corruption or undermining Ukraine. President Obama signed an order allowing sanctions on broad sectors of the Russian economy. The U.S. has also frozen export licenses to Russia and designated more individuals under prior orders. Further sanctions may be imposed if Russia takes additional actions in Ukraine.
The State of the Union and The 2012 Presidential ElectionPatton Boggs LLP
The document discusses President Obama's 2012 State of the Union address and the upcoming presidential election. It provides context on the historically unproductive 112th Congress and challenges facing Obama's reelection campaign due to the economy. While the economy shows signs of improvement, unemployment remains high, posing difficulties for Obama similar to those Reagan faced in 1982. However, Obama may follow the models of Clinton in 1996 and Bush in 2004 by focusing on his base and small issues to bolster his candidacy.
Crimea: U.S. Executive Actions and Legal Implications of Overlapping Global S...Patton Boggs LLP
The document summarizes the recent executive actions taken by the United States and European Union imposing sanctions in response to Russia's annexation of Crimea from Ukraine. It provides details on:
1) The new U.S. Executive Order signed on March 17th authorizing sanctions on senior Russian officials, the Russian arms sector, and those providing support. So far 11 individuals have been sanctioned.
2) The EU publishing a list on March 18th sanctioning 21 Russian and Ukrainian officials, including some also sanctioned by the U.S.
3) The legal implications and scope of sanctions authorized by the new U.S. Executive Order, including asset blocking and visa bans.
DuBow Digest Germany Edition January 27, 2014 dubowdigest
This document provides a summary of several news articles related to the Middle East peace process and Iran nuclear negotiations. It discusses the battle in Washington over new Iran sanctions legislation, with the Obama administration opposing it due to concerns over timing and outcomes. It also describes the activities of Chabad, an international Jewish organization, including their presence and outreach work in Germany and at American universities. The document lists some impediments to peace between Israel and the Palestinians, including the Palestinian demand for a right of return for millions of refugees and their refusal to recognize Israel as a Jewish state.
Corruption, Russia, Procuracy. A law review article co-authored with Mary Holland of NYU Law will be appearing in Columbia Journal of East European Law. The presentation has been given at University of Toronto and elsewhere.
- Bipartisan talks among eight Senators continue on addressing expiring tax cuts and sequestration cuts. The economy added 114,000 jobs in September while the unemployment rate fell.
- The Supreme Court opened its new term reviewing cases on issues like affirmative action, human rights abuses, gay marriage, and the Voting Rights Act.
- President Obama and Mitt Romney debated domestic policy issues in their first presidential debate, with most analyses saying Romney performed better.
This powerpoint was made in the fall of 2019. It describes the basic setup of the US government (the branches set up in the constitution). It touches on how a president can be impeached and how the (then current) impeachment of Trump was progressing.
The document summarizes various domestic and foreign policy matters from July 20, 2012. On domestic issues, it discusses ongoing congressional debates around the fiscal year 2013 budget and efforts to repeal parts of the Affordable Care Act. It also covers developments regarding sequestration and cybersecurity legislation. On foreign policy, key topics included the ongoing civil war in Syria, tensions with Iran over its nuclear program, a terrorist attack in Bulgaria, and trade relations with Russia.
The State of the Union and The 2012 Presidential ElectionPatton Boggs LLP
The document discusses President Obama's 2012 State of the Union address and the upcoming presidential election. It provides context on the historically unproductive 112th Congress and challenges facing Obama's reelection campaign due to the economy. While the economy shows signs of improvement, unemployment remains high, posing difficulties for Obama similar to those Reagan faced in 1982. However, Obama may follow the models of Clinton in 1996 and Bush in 2004 by focusing on his base and small issues to bolster his candidacy.
Crimea: U.S. Executive Actions and Legal Implications of Overlapping Global S...Patton Boggs LLP
The document summarizes the recent executive actions taken by the United States and European Union imposing sanctions in response to Russia's annexation of Crimea from Ukraine. It provides details on:
1) The new U.S. Executive Order signed on March 17th authorizing sanctions on senior Russian officials, the Russian arms sector, and those providing support. So far 11 individuals have been sanctioned.
2) The EU publishing a list on March 18th sanctioning 21 Russian and Ukrainian officials, including some also sanctioned by the U.S.
3) The legal implications and scope of sanctions authorized by the new U.S. Executive Order, including asset blocking and visa bans.
DuBow Digest Germany Edition January 27, 2014 dubowdigest
This document provides a summary of several news articles related to the Middle East peace process and Iran nuclear negotiations. It discusses the battle in Washington over new Iran sanctions legislation, with the Obama administration opposing it due to concerns over timing and outcomes. It also describes the activities of Chabad, an international Jewish organization, including their presence and outreach work in Germany and at American universities. The document lists some impediments to peace between Israel and the Palestinians, including the Palestinian demand for a right of return for millions of refugees and their refusal to recognize Israel as a Jewish state.
Corruption, Russia, Procuracy. A law review article co-authored with Mary Holland of NYU Law will be appearing in Columbia Journal of East European Law. The presentation has been given at University of Toronto and elsewhere.
- Bipartisan talks among eight Senators continue on addressing expiring tax cuts and sequestration cuts. The economy added 114,000 jobs in September while the unemployment rate fell.
- The Supreme Court opened its new term reviewing cases on issues like affirmative action, human rights abuses, gay marriage, and the Voting Rights Act.
- President Obama and Mitt Romney debated domestic policy issues in their first presidential debate, with most analyses saying Romney performed better.
This powerpoint was made in the fall of 2019. It describes the basic setup of the US government (the branches set up in the constitution). It touches on how a president can be impeached and how the (then current) impeachment of Trump was progressing.
The document summarizes various domestic and foreign policy matters from July 20, 2012. On domestic issues, it discusses ongoing congressional debates around the fiscal year 2013 budget and efforts to repeal parts of the Affordable Care Act. It also covers developments regarding sequestration and cybersecurity legislation. On foreign policy, key topics included the ongoing civil war in Syria, tensions with Iran over its nuclear program, a terrorist attack in Bulgaria, and trade relations with Russia.
The US Senate is debating new legislation to authorize military force against ISIS, as the legal authority for current operations comes from the 2001 AUMF passed after 9/11. The Senate bill offers no limits on the scope or duration of operations. However, Democrats oppose its broad scope. Obama favors restrictions but Republicans want to avoid limiting future presidents. Expansive war powers allow Congress to dodge accountability for controversial wars. The debate centers on politics more than legal authority.
The document provides a summary of various domestic and foreign policy matters from the past week. On the domestic front, negotiations continued on averting the fiscal cliff with competing proposals from the White House and House Republicans. Internationally, the US recognized the Syrian opposition coalition and sent missiles to Turkey in response to the conflict in Syria. North Korea launched a long-range rocket, violating UN resolutions. The US also imposed new sanctions on Iran and its nuclear program. Ambassador Rice withdrew her name from consideration for Secretary of State.
Russian Sanctions: What the U.S. and OFAC Directives Mean for Global CompaniesEthisphere
The document provides an overview and summary of recent U.S. sanctions imposed in response to the Russian actions in Ukraine and the implications for global companies. It discusses the sanctions that have designated individuals and entities in Russia, examines entities that may be considered "owned or controlled" by designated persons, and outlines steps companies can take to mitigate risks from potential expansion of sanctions to other sectors of the Russian economy.
Looking Ahead to the Next Administration - Energy Regulation Under Either Tru...Marcellus Drilling News
What happens to the regulatory environment for the energy industry, in particular oil and gas, should Donald Trump win the presidency? What if (perish the thought) Hillary Clinton wins? What can we expect under each administration? That was the theme for the comments by Tom Sansonetti, partner with the Holland and Hart law firm, at the Independent Petroleum Association of America (IPAA) 86th Midyear Meeting, held in Colorado Springs in June 2016.
The Democratic ticket of President Obama and Vice President Biden won the 2012 U.S. Presidential election over Mitt Romney and Paul Ryan, retaining the White House and Senate for Democrats while Republicans maintained control of the House. President Obama has invited Congressional leaders to the White House to begin negotiations to avoid the fiscal cliff of automatic spending cuts and expiring tax cuts. Lawmakers are also considering an initial disaster relief package of $5 billion for areas affected by Hurricane Sandy. On foreign policy, additional sanctions have been placed on Iran and the U.S. is increasing relief efforts in Syria as the humanitarian crisis worsens despite expanding operations. President Obama will travel to Southeast Asia next week to encourage democratic reforms in Burma.
The document provides information on several topics:
1. It discusses the appointment of former FBI chief Robert Mueller as Special Counsel to investigate allegations of collusion between Donald Trump's presidential campaign and Russia.
2. It summarizes the powers and responsibilities of a Special Counsel according to US law and regulations, including their ability to investigate and prosecute federal crimes related to their investigation.
3. It notes that while the Special Counsel is intended to be independent, they are ultimately still subject to oversight and removal by the Attorney General.
A weekly synopsis of trade-related policy developments in Washington, D.C. The Squire Patton Boggs publication is distributed on Fridays, contact the author to be added to the Listserv.
The House and Senate are in recess until after the November 6th elections. On domestic issues, the Senate approved continuing a budget resolution while debates continue over spending cuts. Internationally, Secretary of State Clinton confirmed the attack on the US consulate in Libya was a terrorist attack, while anti-American protests spread in response to an anti-Islamic film. President Obama met with leaders from Burma and Afghanistan to discuss reforms and security issues.
The memorandum provides the following key points:
1) The Carter Page FISA warrant and renewals relied heavily on the Steele dossier, which was funded by the DNC and Clinton campaign. The source's political connections were not disclosed to the FISA court.
2) The FISA application cited a Yahoo News article that was based on leaks from Steele himself, incorrectly assessing that Steele did not directly provide the information.
3) Steele had numerous undisclosed contacts with the media in violation of FBI rules and demonstrated unreliability, yet continued to be cited in warrant applications.
4) Bruce Ohr maintained contact with Steele after he was terminated as a source, and Ohr's wife worked for Fusion
Negotiations over the fiscal cliff continued this week with no agreement. The White House offered a proposal including $1.6 trillion in tax increases and $400 billion in entitlement cuts, but Republicans rejected it. Meanwhile, the House passed a bill to increase visas for skilled immigrants, but the White House did not support the narrow scope. At the UN, Palestine was recognized as a non-member observer state over U.S. objections. In Egypt, an Islamist-dominated assembly approved a constitution without opposition input.
The document summarizes various domestic and foreign policy matters from the previous week. On the domestic front, Congress passed a short-term spending bill to fund the government through March 2013 and debated various appropriations bills. Internationally, the US imposed new sanctions on Iran and supported opposition forces in Syria, while Secretary of State Clinton traveled to several African countries.
The FBI investigated a Congressional trip to Israel over ethics issues involving drinking and swimming. Congressman Todd Akin said women's bodies can prevent pregnancy from "legitimate rape", refusing to withdraw from his Senate race despite criticism. The CBO projected a $1.1 trillion deficit for the current fiscal year and said sharp spending cuts and tax increases risk recession. President Obama warned Syria about chemical weapons while the US monitored sites and France discussed no-fly zones; talks between Iran and the IAEA on its nuclear program ended with no agreement.
1) The document discusses state and local law enforcement's role in enforcing immigration laws. It notes that while the federal government is responsible for immigration enforcement, they lack the resources to do so effectively.
2) It examines how some state and local law enforcement agencies have taken on immigration enforcement duties through programs like 287(g). This allows them to identify and detain undocumented immigrants.
3) However, taking on immigration enforcement can be problematic as it diverts resources away from other law enforcement responsibilities and may damage relationships with immigrant communities. Effective policies and oversight are needed.
The document summarizes recent developments in antitrust legislation and oversight in the 113th United States Congress. There has been one change in leadership for both the Senate and House antitrust subcommittees. In the Senate, Amy Klobuchar now chairs the subcommittee. In the House, Spencer Bachus now chairs the subcommittee. The document outlines several antitrust bills that have been reintroduced from previous Congresses, including ones related to health insurance antitrust exemptions and removing antitrust exemptions for railroads. Only one bill, related to pandemic preparedness, has passed so far. Prospects for most other bills advancing are described as dim due to the divided Congress.
Ch 5 presentation Will Kumi, Rebecca Mendelsohn, Conrad Blackrebeccamendelsohn
The document summarizes key aspects of civil liberties and the Bill of Rights in the United States. It discusses how the Bill of Rights was drafted to limit federal government overreach on individual liberties. It then examines how the 14th Amendment and the incorporation doctrine applied these protections to state laws over time through Supreme Court rulings. Specific rights covered include freedom of religion, speech, press, and assembly. The establishment and free exercise of religion clauses are explained. Tests for determining protected speech like clear and present danger are also summarized.
D&B Briefing: The Economic & Political Situation in the Ukraine | 3/17/14Dun & Bradstreet
D&B has downgraded Ukraine’s country risk rating to DB6c (in our "very high risk" category) from its already poor score of DB6b (on a scale of 1-7, with 7 being the highest possible level of operational risk). The downgrade stems from the significant recent deterioration in the country’s business operating environment. This article gives more insight into the current situation in Ukraine and why their risk rating was downgraded.
PRS’ coverage of the Americas includes a new report on Brazil, where President Dilma Rousseff’s second term has gotten off to a very rocky start, with a widening corruption scandal at state-owned Petrobras that poses a threat to the unity of Rousseff’s legislative coalition. Her political troubles come at a most inopportune time. A sluggish economy and a pre-election spending spree contributed to a widening of the fiscal deficit last year, and the government is under pressure to reassure
This is the presentation, as well as complete notes, for a 45 minute session on the Ukraine Related Sanctions against Russia, given at a Lexis sponsored seminar on Nov 19, 2014. It covers general information on sanctions and compares US and EU sanctions against Russia, as well as touching on Canadian, Swiss, Australian & Japanese sanctions and the outlooks for the future.
Protiviti Flash report details key developments from the first 100 days of the Trump administration, from a business perspective. For more information, go to http://ow.ly/NDPm30bjnfB
The US Senate is debating new legislation to authorize military force against ISIS, as the legal authority for current operations comes from the 2001 AUMF passed after 9/11. The Senate bill offers no limits on the scope or duration of operations. However, Democrats oppose its broad scope. Obama favors restrictions but Republicans want to avoid limiting future presidents. Expansive war powers allow Congress to dodge accountability for controversial wars. The debate centers on politics more than legal authority.
The document provides a summary of various domestic and foreign policy matters from the past week. On the domestic front, negotiations continued on averting the fiscal cliff with competing proposals from the White House and House Republicans. Internationally, the US recognized the Syrian opposition coalition and sent missiles to Turkey in response to the conflict in Syria. North Korea launched a long-range rocket, violating UN resolutions. The US also imposed new sanctions on Iran and its nuclear program. Ambassador Rice withdrew her name from consideration for Secretary of State.
Russian Sanctions: What the U.S. and OFAC Directives Mean for Global CompaniesEthisphere
The document provides an overview and summary of recent U.S. sanctions imposed in response to the Russian actions in Ukraine and the implications for global companies. It discusses the sanctions that have designated individuals and entities in Russia, examines entities that may be considered "owned or controlled" by designated persons, and outlines steps companies can take to mitigate risks from potential expansion of sanctions to other sectors of the Russian economy.
Looking Ahead to the Next Administration - Energy Regulation Under Either Tru...Marcellus Drilling News
What happens to the regulatory environment for the energy industry, in particular oil and gas, should Donald Trump win the presidency? What if (perish the thought) Hillary Clinton wins? What can we expect under each administration? That was the theme for the comments by Tom Sansonetti, partner with the Holland and Hart law firm, at the Independent Petroleum Association of America (IPAA) 86th Midyear Meeting, held in Colorado Springs in June 2016.
The Democratic ticket of President Obama and Vice President Biden won the 2012 U.S. Presidential election over Mitt Romney and Paul Ryan, retaining the White House and Senate for Democrats while Republicans maintained control of the House. President Obama has invited Congressional leaders to the White House to begin negotiations to avoid the fiscal cliff of automatic spending cuts and expiring tax cuts. Lawmakers are also considering an initial disaster relief package of $5 billion for areas affected by Hurricane Sandy. On foreign policy, additional sanctions have been placed on Iran and the U.S. is increasing relief efforts in Syria as the humanitarian crisis worsens despite expanding operations. President Obama will travel to Southeast Asia next week to encourage democratic reforms in Burma.
The document provides information on several topics:
1. It discusses the appointment of former FBI chief Robert Mueller as Special Counsel to investigate allegations of collusion between Donald Trump's presidential campaign and Russia.
2. It summarizes the powers and responsibilities of a Special Counsel according to US law and regulations, including their ability to investigate and prosecute federal crimes related to their investigation.
3. It notes that while the Special Counsel is intended to be independent, they are ultimately still subject to oversight and removal by the Attorney General.
A weekly synopsis of trade-related policy developments in Washington, D.C. The Squire Patton Boggs publication is distributed on Fridays, contact the author to be added to the Listserv.
The House and Senate are in recess until after the November 6th elections. On domestic issues, the Senate approved continuing a budget resolution while debates continue over spending cuts. Internationally, Secretary of State Clinton confirmed the attack on the US consulate in Libya was a terrorist attack, while anti-American protests spread in response to an anti-Islamic film. President Obama met with leaders from Burma and Afghanistan to discuss reforms and security issues.
The memorandum provides the following key points:
1) The Carter Page FISA warrant and renewals relied heavily on the Steele dossier, which was funded by the DNC and Clinton campaign. The source's political connections were not disclosed to the FISA court.
2) The FISA application cited a Yahoo News article that was based on leaks from Steele himself, incorrectly assessing that Steele did not directly provide the information.
3) Steele had numerous undisclosed contacts with the media in violation of FBI rules and demonstrated unreliability, yet continued to be cited in warrant applications.
4) Bruce Ohr maintained contact with Steele after he was terminated as a source, and Ohr's wife worked for Fusion
Negotiations over the fiscal cliff continued this week with no agreement. The White House offered a proposal including $1.6 trillion in tax increases and $400 billion in entitlement cuts, but Republicans rejected it. Meanwhile, the House passed a bill to increase visas for skilled immigrants, but the White House did not support the narrow scope. At the UN, Palestine was recognized as a non-member observer state over U.S. objections. In Egypt, an Islamist-dominated assembly approved a constitution without opposition input.
The document summarizes various domestic and foreign policy matters from the previous week. On the domestic front, Congress passed a short-term spending bill to fund the government through March 2013 and debated various appropriations bills. Internationally, the US imposed new sanctions on Iran and supported opposition forces in Syria, while Secretary of State Clinton traveled to several African countries.
The FBI investigated a Congressional trip to Israel over ethics issues involving drinking and swimming. Congressman Todd Akin said women's bodies can prevent pregnancy from "legitimate rape", refusing to withdraw from his Senate race despite criticism. The CBO projected a $1.1 trillion deficit for the current fiscal year and said sharp spending cuts and tax increases risk recession. President Obama warned Syria about chemical weapons while the US monitored sites and France discussed no-fly zones; talks between Iran and the IAEA on its nuclear program ended with no agreement.
1) The document discusses state and local law enforcement's role in enforcing immigration laws. It notes that while the federal government is responsible for immigration enforcement, they lack the resources to do so effectively.
2) It examines how some state and local law enforcement agencies have taken on immigration enforcement duties through programs like 287(g). This allows them to identify and detain undocumented immigrants.
3) However, taking on immigration enforcement can be problematic as it diverts resources away from other law enforcement responsibilities and may damage relationships with immigrant communities. Effective policies and oversight are needed.
The document summarizes recent developments in antitrust legislation and oversight in the 113th United States Congress. There has been one change in leadership for both the Senate and House antitrust subcommittees. In the Senate, Amy Klobuchar now chairs the subcommittee. In the House, Spencer Bachus now chairs the subcommittee. The document outlines several antitrust bills that have been reintroduced from previous Congresses, including ones related to health insurance antitrust exemptions and removing antitrust exemptions for railroads. Only one bill, related to pandemic preparedness, has passed so far. Prospects for most other bills advancing are described as dim due to the divided Congress.
Ch 5 presentation Will Kumi, Rebecca Mendelsohn, Conrad Blackrebeccamendelsohn
The document summarizes key aspects of civil liberties and the Bill of Rights in the United States. It discusses how the Bill of Rights was drafted to limit federal government overreach on individual liberties. It then examines how the 14th Amendment and the incorporation doctrine applied these protections to state laws over time through Supreme Court rulings. Specific rights covered include freedom of religion, speech, press, and assembly. The establishment and free exercise of religion clauses are explained. Tests for determining protected speech like clear and present danger are also summarized.
D&B Briefing: The Economic & Political Situation in the Ukraine | 3/17/14Dun & Bradstreet
D&B has downgraded Ukraine’s country risk rating to DB6c (in our "very high risk" category) from its already poor score of DB6b (on a scale of 1-7, with 7 being the highest possible level of operational risk). The downgrade stems from the significant recent deterioration in the country’s business operating environment. This article gives more insight into the current situation in Ukraine and why their risk rating was downgraded.
PRS’ coverage of the Americas includes a new report on Brazil, where President Dilma Rousseff’s second term has gotten off to a very rocky start, with a widening corruption scandal at state-owned Petrobras that poses a threat to the unity of Rousseff’s legislative coalition. Her political troubles come at a most inopportune time. A sluggish economy and a pre-election spending spree contributed to a widening of the fiscal deficit last year, and the government is under pressure to reassure
This is the presentation, as well as complete notes, for a 45 minute session on the Ukraine Related Sanctions against Russia, given at a Lexis sponsored seminar on Nov 19, 2014. It covers general information on sanctions and compares US and EU sanctions against Russia, as well as touching on Canadian, Swiss, Australian & Japanese sanctions and the outlooks for the future.
Protiviti Flash report details key developments from the first 100 days of the Trump administration, from a business perspective. For more information, go to http://ow.ly/NDPm30bjnfB
The situa on in Ukraine escalated sharply in April as armed insurgents seized buildings in Dontesk and Lugansk. Nego a ons in Geneva agreed to disarmament but the insurgents defied the agreement. Russia keeps demanding Ukraine stop using force but has unclear control over the insurgents. Russia faces tougher sanc ons if it intervenes further in Ukraine. Domes cally, Russia amended laws on ci zenship and elec ons to ghten eligibility and signature requirements, and passed a first reading abolishing direct mayoral elec ons.
The document discusses sanctions that have been imposed on Russia by the US and EU in response to Russia's actions in Ukraine. It provides an overview of the legal frameworks establishing the sanctions in the EU and US and how they affect business interactions. The sanctions prohibit economic contacts and transactions with sanctioned individuals and entities. They also affect foreign subsidiaries of US and EU companies and private citizens from the US and EU. The sanctions are having indirect economic impacts, such as increased financing costs for companies doing business with Russia. Exceptions to the sanctions allow certain pre-existing contracts and humanitarian activities.
The USA Patriot Act was passed in 2001 as a response to the September 11th terrorist attacks. It made several controversial changes to surveillance laws that granted the government expanded powers to monitor communications and financial and medical records. While intended to help prevent terrorism, many felt certain provisions violated civil liberties and privacy protections. The act faced several legal challenges over its most controversial aspects and their application in cases of suspected but ultimately wrongful terrorism accusations.
This document provides a summary of sanctions and export controls enforced by the Office of Foreign Asset Controls (OFAC) and the Bureau of Industry and Security (BIS) on trade with sanctioned regions. It notes that OFAC and BIS enforcement is increasing given ongoing conflicts. While a nuclear deal with Iran may relax some sanctions, US firms will still be largely barred from investing there. The document also advises being wary of suspicious client behavior that could indicate export diversions.
Michael MoratzWhat specific legal action and against who, ha.docxARIV4
Michael Moratz
What specific legal action and against who, has the U.S. government undertaken resulting from, or linked to, this EO?
There are multiple regulations imposed under Executive Order (EO) 13382 that also link to Executive 12938 and 31 C.F.R Section 539. If we break EO 13382 down, the specific legal action imposed include three separate sanctions programs. First, EO 13382, “blocks the property of persons engaged in proliferation activities and their support networks (OFAC, 2012).” Second, EO 13382, implements “a ban on imports into the United States, pursuant to Executive Order 12938 (OFAC, 2012).” EO 12938 empowers the Secretary of the Treasury to prohibit the importation of goods, technology, or services by a foreign person who participates in WMD proliferation activities. Third, EO 13382 blocks the Russian Federation from doing anything with their highly enriched uranium stockpiles other than what has already been agreed upon with the U.S. (OFAC, 2012). In summary, executive order 13382, “denies those parties access to the U.S. financial and commercial systems (OFAC, 2012).” Which means entities and their supporters that deal in WMD proliferation are subject to denial to the US financial systems and having their assets frozen.
Executive Order 13382 affects many different international entities from multiple countries. EO 13382 initially applied to eight organizations within the countries of North Korea, Iran, and Syria. However, the EO allows the Secretary of the Treasury in conjunction with the Secretary of State to impose sanctions on additional entities and their supporters who conduct WMD proliferation activities. The current list of “foreign persons” under “active” import bans pursuant to EO 12938 includes about 205 entities or their supporters (DOS, 2016). EO 13382 also affects the Russian Federation, who has further restrictions emplaced, in regards to their blend down of highly enriched uranium to low enriched uranium. Specifically, over a twenty-year period the Russian Federation will reduce 500 metric tons to low enriched uranium for use in commercial reactors (OFAC, 2012). Furthermore, EO 13382 blocks U.S. persons or companies and their foreign branches from engaging in any transaction with any party designed by the order.
Executive Order 13382 basically creates an easier way for the executive branch of the United States Government to impose sanctions. The language in the order is broad and places the burden of sanctions on the Secretary of the Treasury and the Secretary of State. Meaning, Congress does not get a vote and the process of placing international sanctions on foreign entities or property in the possession of U.S. citizens is streamlined (Crail, 2008). Which allows for the question of, without legislation authorizing sanctions have all legal standards set by Congress been met? An Executive Order that is upheld by the judicial branch can clear up the mud ...
The document discusses the practical impacts of sanctions imposed by the EU and US against Russia in response to the Crimea crisis. It outlines the legal framework of the sanctions, noting that they prohibit economic interactions with over 160 sanctioned individuals and entities. While the sanctions directly target those on the lists, they are also having indirect economic effects, such as rising credit costs for both Western and Russian companies doing business in or with Russia due to increased risk perceptions from banks and investors. Exceptions to the sanctions allow for certain pre-existing contracts and humanitarian aid.
you have to complete the following readingIan Bogost, Program.docxodiliagilby
you have to complete the following reading:
Ian Bogost, Programmers: Stop Calling Yourselves Engineers. In The Atlantic, November, 2015. Available at: https://www.theatlantic.com/technology/archive/2015/11/programmers-should-not-call-themselves-engineers/414271
short answers to the following questions (no more than 100 words per question):
1.What are the origins of the phrase “software engineering”?
2.What are the differences between software engineering and the traditional disciplines of engineering?
3.What is the author’s opinion about the Scrum method and why?
US President Donald J. Trump’s administration has found it chal-lenging to maintain a consistent position with respect to Russian President Vladimir Putin’s repression at home and aggression abroad. The US president’s accommodating language about Putin;
his mixed messages about Ukraine, a country defending itself against Russian
attack; and frequent refusal to recognize Kremlin interference in the US elec-
tion process seem at odds with the generally stronger position of the admin-
istration as a whole. Given this inconsistency, it may again fall to Congress
to attempt to counter Russia’s election interference, already ongoing in the
form of disinformation; back Ukraine as its government seeks to deal with a
Russian invasion; and contend with other forms of Kremlin aggression.
The authors of this issue brief are executive branch veterans and admit to
general skepticism about making foreign policy through legislation, particu-
Pushing Back Against
Russian Aggression:
Legislative Options
ISSUE BRIEF
MARCH 2020 DANIEL FRIED AND BRIAN O’TOOLE
The Atlantic Council’s Global Business
& Economics Program (GBE) promotes
transatlantic leadership as defenders
of open market democracies in a new
era of great-power competition and
works to find multilateral solutions to
today’s most pressing global economic
opportunities and risks. Key challenges
the program addresses include
fostering broad-based economic
growth, advancing understanding of
the impact of economic sanctions, and
defining the future shape of the rule-
based trade order.
Atlantic Council
GLOBAL BUSINESS
& ECONOMICS PROGRAM
Economic sanctions have become a policy tool-of-choice for the US govern-
ment. Yet sanctions and their potential pitfalls are often misunderstood. The
Economic Sanctions Initiative (ESI) seeks to build a better understanding of
the role sanctions can and cannot play in advancing policy objectives and of
the impact of economic statecraft on the private sector, which bears many of
the implementation costs.
2 ATLANTIC COUNCIL
ISSUE BRIEF Pushing Back Against Russian Aggression: Legislative Options
larly in nuanced matters that the executive is better struc-
tured to address. However, such legislation is sometimes
needed. In 2017, in response to reasonable concerns that
the new Trump administration was considering a unilateral
rescission of Russia sanctions imposed afte ...
you have to complete the following readingIan Bogost, Program.docxdavezstarr61655
you have to complete the following reading:
Ian Bogost, Programmers: Stop Calling Yourselves Engineers. In The Atlantic, November, 2015. Available at: https://www.theatlantic.com/technology/archive/2015/11/programmers-should-not-call-themselves-engineers/414271
short answers to the following questions (no more than 100 words per question):
1.What are the origins of the phrase “software engineering”?
2.What are the differences between software engineering and the traditional disciplines of engineering?
3.What is the author’s opinion about the Scrum method and why?
US President Donald J. Trump’s administration has found it chal-lenging to maintain a consistent position with respect to Russian President Vladimir Putin’s repression at home and aggression abroad. The US president’s accommodating language about Putin;
his mixed messages about Ukraine, a country defending itself against Russian
attack; and frequent refusal to recognize Kremlin interference in the US elec-
tion process seem at odds with the generally stronger position of the admin-
istration as a whole. Given this inconsistency, it may again fall to Congress
to attempt to counter Russia’s election interference, already ongoing in the
form of disinformation; back Ukraine as its government seeks to deal with a
Russian invasion; and contend with other forms of Kremlin aggression.
The authors of this issue brief are executive branch veterans and admit to
general skepticism about making foreign policy through legislation, particu-
Pushing Back Against
Russian Aggression:
Legislative Options
ISSUE BRIEF
MARCH 2020 DANIEL FRIED AND BRIAN O’TOOLE
The Atlantic Council’s Global Business
& Economics Program (GBE) promotes
transatlantic leadership as defenders
of open market democracies in a new
era of great-power competition and
works to find multilateral solutions to
today’s most pressing global economic
opportunities and risks. Key challenges
the program addresses include
fostering broad-based economic
growth, advancing understanding of
the impact of economic sanctions, and
defining the future shape of the rule-
based trade order.
Atlantic Council
GLOBAL BUSINESS
& ECONOMICS PROGRAM
Economic sanctions have become a policy tool-of-choice for the US govern-
ment. Yet sanctions and their potential pitfalls are often misunderstood. The
Economic Sanctions Initiative (ESI) seeks to build a better understanding of
the role sanctions can and cannot play in advancing policy objectives and of
the impact of economic statecraft on the private sector, which bears many of
the implementation costs.
2 ATLANTIC COUNCIL
ISSUE BRIEF Pushing Back Against Russian Aggression: Legislative Options
larly in nuanced matters that the executive is better struc-
tured to address. However, such legislation is sometimes
needed. In 2017, in response to reasonable concerns that
the new Trump administration was considering a unilateral
rescission of Russia sanctions imposed afte.
This is the second session of a three day course on economic sanctions related to Russia. It covers the financing restrictions from the US and EU sanctions generally.
Part 2 - Perfect overview on economic sanctions - US & EUPavel Melnikov
2nd part of a perfect overview on economic sanctions made by Marian Dent from Pericles. Elaborating and answering such key questions on sanctions like Who, Against whom, What, Why & How to comply
What Congress has to get done before Dec 31st 2014 Votetocracy
Contains a detailed review of what Congress has to get done by the end of 2014. Including deadline driven legislation and critical issues such as ISIS, Minimum Wage, Ban on Internet Taxes, Ukraine, Border Control and more.
View the most recent commentary from The PRS Group on international macro risk.
This month’s reporting in the Americas includes a new report on Cuba, where the implementation of market-based reforms aimed at shoring up the economic foundation ahead of a planned generational transfer of power within the governing PCC has yet to generate a substantial increase...
Article assignment ndaa 2012 indefinate detention and loss of due process of lawWayne Williams
Students will examine the National Defense Authorization Act of 2012; specifically, Clauses 1021 and 1022 and the loss of citizens rights to due process of law.
Advisory on Widespread Public Corruption in VenezuelaRaaj Khanna
1. The document is an advisory from FinCEN alerting financial institutions of widespread public corruption in Venezuela and methods corrupt Venezuelan officials may use to move and hide corruption proceeds, including through abuse of government contracts and shell companies.
2. The advisory provides financial red flags for transactions involving Venezuelan government agencies, state-owned enterprises, and currency controls that could be indicative of money laundering related to Venezuelan public corruption.
3. Financial institutions are reminded of their regulatory obligations to monitor private accounts, correspondent accounts, and file SARs related to transactions suspected of involving Venezuelan corruption proceeds.
President Obama issued three executive orders imposing sanctions on individuals and entities responsible for undermining Ukraine's sovereignty. The sanctions restricted travel and imposed financial costs on Russia. The US sanctioned Russian and Ukrainian officials and companies, limited credit to Russian banks, and restricted exports related to Russia's energy sector. These coordinated actions with international partners aimed to make clear there are consequences for violating Ukraine's territorial integrity and encourage Russia to respect its international obligations regarding Ukraine.
# 151053 Cust Cengage Au Hall Pg. No. iii Title Cri.docxAASTHA76
The document discusses the structure of the American legal system, specifically focusing on federalism and the division of power between federal and state governments. It explains that the US has a dual sovereignty system with both federal and state governments having authority over citizens. While most crimes fall under state jurisdiction, some areas like counterfeiting are exclusively under federal control. The expansion of federal power, especially through the Commerce Clause, has increased concurrent jurisdiction between federal and state governments. However, the Supreme Court has also reaffirmed the important role of states in regulating health, safety, and welfare through their police powers.
Federal agencies play the primary role in policing and regulating white collar crime. The key agencies include the Department of Justice for criminal prosecution, the FBI for corporate scandals, and Inspectors General for auditing companies. Regulatory agencies aim to control business behavior and ensure market stability and protection of workers, consumers, and citizens. The SEC was established in 1934 following the Great Depression to restore investor confidence and oversee stock market trading and participants through requirements for full disclosure and prohibiting certain harmful activities.
Similar to Crimea: U.S. Response Intensifies As Congress, President Obama Issue More Sanctions (20)
Update: Employer Responsibilities Under the Affordable Care ActPatton Boggs LLP
This document summarizes employer responsibilities under the Affordable Care Act that take effect in January 2015. It outlines key timelines employers should be aware of, including penalties for employers with 50 or more full-time employees in 2016. It provides guidance on determining if a company qualifies as a large employer based on number of full-time equivalent employees. It also discusses options for employers who are subject to penalties, such as providing affordable health insurance or paying penalties.
Protecting Patient Information - Feds Find Security Lapses in State and Local...Patton Boggs LLP
This document summarizes two recent announcements from the Department of Health and Human Services highlighting the need for state and local governments to regularly review their policies and procedures for protecting patient health information. An audit found serious cybersecurity lapses in 10 state Medicaid systems, including lack of security plans, encryption of laptops, and disaster recovery testing. Additionally, Skagit County, Washington agreed to a $215,000 settlement for exposing patient information on a public server in violation of privacy and security rules. Both announcements emphasize the importance of risk assessments, administrative and technical safeguards, and compliance with health information privacy laws.
American University International Law Review Annual Symposium: Managing the G...Patton Boggs LLP
DC Partner Frank Samolis will address participants during a symposium hosted by American University’s Washington College of Law on February 18, 2014. The event will examine issues around international trade and the environment through dialogue on the Trans-Pacific Partnership and Transatlantic Trade and Investment Partnership negotiations, the state of Article XX of the General Agreement on Tariffs and Trade, enforcement mechanisms under regional trade agreements, and potential future means of protecting the environment through International Trade Law Society. Mr. Samolis will serve as a panelist during a discussion on TTP talks and TTIP negotiations at 12:45 p.m. during the symposium.
This newsletter provides summaries of recent reinsurance case law and regulatory developments from March 2014. It includes summaries of cases from New York, Tennessee, and California federal courts related to arbitration awards, protected cell reinsurance agreements, preclusion of subsequent arbitrations, and common interest privilege with reinsurers. It also summarizes cases related to tax treatment of retrocessional agreements, dismissal of defenses in a facultative reinsurance dispute, denial of stay in a mortgage reinsurance case, and assumption versus reinsurance.
With increasing demand on limited public resources, national and local governments are recognizing the need for a new approach to social services that emphasizes the identification of effective, innovative ideas. However, a lack of available funding and the reluctance to take on the risk that a promising, but unproven, idea might fail have created obstacles to this new approach. The social impact bond model is designed to eliminate these obstacles.
Supreme Court Agrees to Hear Two Cases on Attorneys' Fees in Patent CasesPatton Boggs LLP
The Supreme Court agreed to hear two cases that deal with awarding attorneys' fees in patent cases. In the first case, Octane Fitness v. ICON Health, the Court will consider whether to lower the standard for determining an "exceptional case" in which fees can be awarded. In the second case, Highmark v. Allcare Health, the Court will determine how much deference appellate courts must give to lower court decisions on awarding fees. These rulings could make it easier for prevailing parties to recoup fees and deter patent holders from filing weak infringement claims.
FTC Announces Study of "Patent Assertion Entities"Patton Boggs LLP
The FTC announced it will conduct a study of patent assertion entities (PAEs) by collecting detailed information from 25 PAEs and 15 other companies through its authority under Section 6(b) of the FTC Act. The FTC will seek information about PAE operations, patent acquisitions, assertion activities like litigation and licensing, costs and revenues. Responding companies may be able to keep some information confidential, but it could also be subject to disclosure. The FTC must get approval from the OMB before collecting information and is seeking public comment on the study by December 2nd.
ALJ Ruling on Heart Attack Reporting Requirements Creates Split of AuthorityPatton Boggs LLP
1) An ALJ ruled that an employee's heart attack at a mine did not constitute an "injury" requiring immediate reporting under MSHA regulations, creating a split with previous ALJ decisions.
2) The regulations require immediate reporting of accidents involving injury with a potential for death; the ALJ found a heart attack was an illness, not an injury.
3) However, the ALJ distinguished cases where CPR was required or the victim was unresponsive, requiring immediate reporting in those scenarios still. The full Commission has yet to address this issue definitively.
New TCPA Requirements for "Prior Express Written Consent" Effective October 16Patton Boggs LLP
This document summarizes new requirements under the Telephone Consumer Protection Act (TCPA) for obtaining "prior express written consent" before making telemarketing calls or texts. Beginning October 16, 2013, companies must get written permission that specifically authorizes automated calls or prerecorded messages to wireless or residential lines. The rules also eliminate exceptions for current customers and require consent for each phone number. Violations of the new consent rules could result in substantial damages in consumer lawsuits. Companies are advised to review their practices to ensure compliance.
This newsletter provides summaries of recent reinsurance cases:
1) The US Supreme Court clarified that arbitrators have broad authority to interpret contracts and their decisions should not be overturned even if their interpretation is incorrect, as long as they construed the contract.
2) A California court ordered parties to complete their arbitrator selection process and let the panel decide issues of consolidation and contractual provisions, rather than the court making those decisions.
3) A Connecticut court compelled arbitration in a fronting dispute, finding the reinsurer agreed to arbitrate based on references to underlying reinsurance agreements in an assumption agreement.
The newsletter also provides brief summaries of several other reinsurance court cases.
The U.S. Chemical Safety Board to OSHA: Get to Work on Combustible DustPatton Boggs LLP
The Chemical Safety Board held a meeting on July 25, 2013 where it designated the development of an Occupational Safety and Health Administration (OSHA) standard for combustible dust as its top priority. The Board criticized OSHA for failing to advance this regulatory process since 2009. It deemed OSHA's response to recommendations regarding combustible dust standards as "unacceptable." The alert discusses the implications of this designation, including that it could spur OSHA to resume its rulemaking process for a combustible dust standard, which would impact various industries if finalized.
The Transatlantic Trade and Investment Partnership: The Intersection of the I...Patton Boggs LLP
This document summarizes a client alert from the law firm PattonBoggs regarding the Transatlantic Trade and Investment Partnership (TTIP) negotiations between the EU and US. It notes that digital commerce and data privacy will be key issues discussed, as the EU and US have different approaches to these matters. Specifically, the EU views data privacy as a fundamental right while the US takes a sector-specific approach. Recent NSA surveillance revelations have heightened these differences. The next round of TTIP talks in October will likely start substantive discussions on finding common ground regarding data privacy standards.
The document provides a summary of legislative activities in the United States Congress for the week of July 29, 2013. In the Senate, cloture was filed on several nominations including the nomination of James Comey as FBI Director. The Senate also passed a bill tying student loan interest rates to Treasury rates. In the House, the agenda for the week includes consideration of an appropriations bill and several other pieces of legislation under suspension of the rules. The document also summarizes legislative activities relating to various policy areas such as agriculture, budget, cybersecurity, and defense.
This document provides a summary of legislative activity in Congress for the week of July 22, 2013. It covers developments in various policy areas including the farm bill, appropriations bills, cybersecurity legislation, and hearings scheduled. The Senate is expected to take up the transportation appropriations bill this week but there may be a budget point of order raised. The House will consider the defense appropriations bill but there are disagreements over amendments. In cybersecurity, a Senate committee plans to mark up a bipartisan bill by the end of the month focusing on NIST coordination and workforce issues.
The document is a summary of frequently asked questions from the CFTC's cross-border guidance. It defines key terms like U.S. person, foreign branch, and affiliate conduit. For U.S. person, it provides a broad definition that includes natural persons residing in the U.S., entities organized in the U.S., certain trusts, collective investment vehicles majority-owned by U.S. persons, and entities with unlimited liability that are majority-owned by U.S. persons. It also considers factors like a party's connections to U.S. commerce in determining U.S. person status. For foreign branches, it notes they are considered part of the principal U.S. entity but may
Tony Abbott and the conservative National Liberal Coalition secured a landslide victory over the Labor party in Australia's federal election. Abbott stated that Australia is now "under new management and open for business." The Coalition is expected to focus on economic policy, including repealing the carbon tax, increasing infrastructure spending, returning the budget to surplus, and abandoning Labor's emissions trading policy in favor of a direct action climate plan. Julie Bishop will remain as Australian ambassador to the United States, and Kevin Rudd has stepped down as Labor leader.
"Advance Australia Fair" - The Australian Federal Election 2013Patton Boggs LLP
This document summarizes the key issues of the upcoming Australian federal election on September 7, 2013. It outlines the stances of the ruling Labour Party and opposition Liberal National Coalition on climate change, the economy, national security, and asylum seekers. On climate change, Labour supports moving to an emissions trading scheme while the Coalition prefers "direct action." Both parties aim to reduce carbon emissions by 5% by 2020 but the Coalition has made no commitments beyond that. The economy and returning the budget to surplus are also major issues. National security policies focus on continued US defense cooperation and engagement in the Indian Ocean region. The parties differ on their approaches to offshore processing of asylum seekers.
U.S. Securities and Exchange Commission Proposes New Rule on Pay DisclosurePatton Boggs LLP
The SEC proposed a new rule that would require public companies to disclose the ratio of the compensation of its principal executive officer to the median compensation of all employees. The rule is meant to provide transparency on pay disparity and rein in bloated executive pay. It allows companies flexibility in calculating median pay and identifying employees. Companies can use statistical sampling or other reasonable methods. They can make reasonable estimates and do not need to include contractors. The ratio must be expressed as a ratio or narrative multiple. Companies must disclose their methodology and assumptions. The rule applies to companies already providing executive pay disclosure but provides exemptions for smaller companies.
This document provides answers to legal questions about hotel operations in the Arabian Gulf. It discusses identifying an appropriate hotel operator through comparing terms, conducting due diligence, and ensuring a good relationship fit. It also covers establishing a corporate presence, employing hotel staff, performance requirements, financial safeguards, governing law, and dispute resolution mechanisms. The document was written by lawyers at Patton Boggs LLP who have significant experience advising hotel owners and operators on projects in the region.
Non-Practicing Entity Sued Under RICO for Bringing Allegedly Frivolous Patent...Patton Boggs LLP
The document summarizes a lawsuit filed by FindTheBest.com (FTB) against Lumen View Technology and associated individuals and entities. FTB alleges that Lumen is a non-practicing entity that brings serial patent infringement lawsuits without merit in order to extort settlements. Specifically, FTB claims that Lumen uses threats of expensive litigation and damage to businesses to coerce "licensing fees" from targets even though their technologies do not actually infringe Lumen's patents. FTB sued Lumen under RICO and various state laws, seeking damages and injunctive relief. This type of RICO counterclaim against serial litigators is an emerging strategy in response to allegedly frivolous patent infringement claims.
लालू यादव की जीवनी LALU PRASAD YADAV BIOGRAPHYVoterMood
Discover the life and times of Lalu Prasad Yadav with a comprehensive biography in Hindi. Learn about his early days, rise in politics, controversies, and contribution.
12062024_First India Newspaper Jaipur.pdfFIRST INDIA
Find Latest India News and Breaking News these days from India on Politics, Business, Entertainment, Technology, Sports, Lifestyle and Coronavirus News in India and the world over that you can't miss. For real time update Visit our social media handle. Read First India NewsPaper in your morning replace. Visit First India.
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16062024_First India Newspaper Jaipur.pdfFIRST INDIA
Find Latest India News and Breaking News these days from India on Politics, Business, Entertainment, Technology, Sports, Lifestyle and Coronavirus News in India and the world over that you can't miss. For real time update Visit our social media handle. Read First India NewsPaper in your morning replace. Visit First India.
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ग्रेटर मुंबई के नगर आयुक्त को एक खुले पत्र में याचिका दायर कर 540 से अधिक मुंबईकरों ने सभी अवैध और अस्थिर होर्डिंग्स, साइनबोर्ड और इलेक्ट्रिक साइनेज को तत्काल हटाने और 13 मई, 2024 की शाम को घाटकोपर में अवैध होर्डिंग के गिरने की विनाशकारी घटना के बाद अपराधियों के खिलाफ सख्त कार्रवाई की मांग की है, जिसमें 17 लोगों की जान चली गई और कई निर्दोष लोग गंभीर रूप से घायल हो गए।
projet de traité négocié à Istanbul (anglais).pdfEdouardHusson
Ceci est le projet de traité qui avait été négocié entre Russes et Ukrainiens à Istanbul en mars 2022, avant que les Etats-Unis et la Grande-Bretagne ne détournent Kiev de signer.
13062024_First India Newspaper Jaipur.pdfFIRST INDIA
Find Latest India News and Breaking News these days from India on Politics, Business, Entertainment, Technology, Sports, Lifestyle and Coronavirus News in India and the world over that you can't miss. For real time update Visit our social media handle. Read First India NewsPaper in your morning replace. Visit First India.
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Slide deck with charts from our Digital News Report 2024, the most comprehensive exploration of news consumption habits around the world, based on survey data from more than 95,000 respondents across 47 countries.
15062024_First India Newspaper Jaipur.pdfFIRST INDIA
Find Latest India News and Breaking News these days from India on Politics, Business, Entertainment, Technology, Sports, Lifestyle and Coronavirus News in India and the world over that you can't miss. For real time update Visit our social media handle. Read First India NewsPaper in your morning replace. Visit First India.
CLICK:- https://firstindia.co.in/
#First_India_NewsPaper
Recent years have seen a disturbing rise in violence, discrimination, and intolerance against Christian communities in various Islamic countries. This multifaceted challenge, deeply rooted in historical, social, and political animosities, demands urgent attention. Despite the escalating persecution, substantial support from the Western world remains lacking.
केरल उच्च न्यायालय ने 11 जून, 2024 को मंडला पूजा में भाग लेने की अनुमति मांगने वाली 10 वर्षीय लड़की की रिट याचिका को खारिज कर दिया, जिसमें सर्वोच्च न्यायालय की एक बड़ी पीठ के समक्ष इस मुद्दे की लंबित प्रकृति पर जोर दिया गया। यह आदेश न्यायमूर्ति अनिल के. नरेंद्रन और न्यायमूर्ति हरिशंकर वी. मेनन की खंडपीठ द्वारा पारित किया गया
Federal Authorities Urge Vigilance Amid Bird Flu Outbreak | The Lifesciences ...The Lifesciences Magazine
Federal authorities have advised the public to remain vigilant but calm in response to the ongoing bird flu outbreak of highly pathogenic avian influenza, commonly known as bird flu.
#WenguiGuo#WashingtonFarm Guo Wengui Wolf son ambition exposed to open a far...rittaajmal71
Since fleeing to the United States in 2014, Guo Wengui has founded a number of projects in the United States, such as GTV Media Group, GTV private equity, farm loan project, G Club Operations Co., LTD., and Himalaya Exchange.
17062024_First India Newspaper Jaipur.pdfFIRST INDIA
Find Latest India News and Breaking News these days from India on Politics, Business, Entertainment, Technology, Sports, Lifestyle and Coronavirus News in India and the world over that you can't miss. For real time update Visit our social media handle. Read First India NewsPaper in your morning replace. Visit First India.
CLICK:- https://firstindia.co.in/
#First_India_NewsPaper
Crimea: U.S. Response Intensifies As Congress, President Obama Issue More Sanctions
1. APRIL 1, 2014
This alert provides only general
information and should not be
relied upon as legal advice.
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attorney advertising under
court and bar rules in certain
jurisdictions.
For more information, contact
your Patton Boggs LLP attorney
or the authors listed below.
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PattonBoggs.com Client Alert: Crimea: U.S. Response Intensifies 1
INTERNATIONAL BUSINESS CLIENT ALERT
CRIMEA: U.S. RESPONSE INTENSIFIES
AS CONGRESS, PRESIDENT OBAMA
ISSUE MORE SANCTIONS
The U.S. government recently has taken a number of actions to intensify its
response to the Russian Federation. Today, the House passed by a vote of 378-
34 the Support for the Sovereignty, Integrity, Democracy, and Economic
Stability of Ukraine Act of 2014 (Ukraine Act, H.R. 4152), as amended and
passed by the Senate on March 27. It provides financial support to Ukraine and
authorizes the imposition of further sanctions against the Russian Federation.
U.S. President Barack Obama has announced that he will sign this bill into law.
On March 20, the U.S. Treasury imposed sanctions against additional Russian
politicians and business leaders and one Russian bank under Executive Order
13661, and President Obama signed a third, broader Executive Order (E.O.
13662) authorizing the imposition of additional sanctions against broad
categories of individuals and economic sectors in Russia. While the third E.O.
creates the legal framework for additional sector-based sanctions, the Obama
administration has not yet sanctioned any individuals or entities pursuant to its
authority.
On March 27, the Department of Commerce Bureau of Industry and Security
(BIS) and the Department of State Directorate of Defense Trade Controls
(DDTC) disclosed that they had stopped processing applications for U.S.
business licenses to export items to Russia on March 1, reflecting administration
effort to put additional pressure on Moscow.
ANALYSIS OF RECENT CONGRESSIONAL ACTION
The Ukraine Act provides financial support to Ukraine, authorizes sanctions
against categories of Ukrainian and Russian persons already targeted by the three
Executive Orders as well as persons responsible for corruption in Russia, and
authorizes the appropriation of funds for security and civil society programs in
Eastern and Central Europe. It does not contain controversial provisions to
ratify reforms to the International Monetary Fund.
2. PattonBoggs.com Client Alert: Crimea: U.S. Response Intensifies 2
Specifically, the new legislation authorizes sanctions against the following persons:
1. Any person who ordered, controlled, directed, or perpetrated significant acts of violence or gross human
rights abuses against anti-government protesters in Ukraine;
2. Any person who ordered, controlled, directed, or perpetrated significant acts (including economic
extortion) to undermine the peace, security, sovereignty, or territorial integrity of Ukraine;
3. Any Russian government official, close associate, or family member who is responsible for, complicit in,
ordered, controlled, or directed acts of significant corruption in Ukraine;
4. Any individual who materially assisted, sponsored, or provided financial, material, or technological support
for, or goods or services in support of the above acts; and
5. Any person who orders, controls, directs, or perpetrates significant acts of corruption in Russia.
As passed, the new legislation does not mandate an expansion of U.S. sanctions targeting Russia, but it provides
additional authority for the Obama administration to designate more Russian persons in the future, even if the
Executive Orders are lifted.
While the first four categories of sanctioned persons largely mirror those announced by the Obama
administration in the first three Executive Orders, the fifth category expands U.S. sanctions to include persons
responsible for corruption in Russia. This largely reflects Congress’ current willingness to give deference to the
President on the issue of Russia sanctions, but this political perspective is likely to change if there is a further
escalation of the crisis.
Sanctions bills have been increasingly popular in Congress, and passing the Ukraine Act allows lawmakers to
show strong action in response to the situation in Ukraine, which is an important political consideration in
advance of the mid-term elections in November 2014. Like the three Executive Orders issued by President
Obama, the legislation authorizes the following sanctions against the above categories of persons:
→ Asset blocking: Any person or entity meeting the above criteria may be listed as a Specially
Designated National (SDN) by the U.S. Department of the Treasury’s Office of Foreign Assets
Control (OFAC).
→ Visa bans or revocations: The U.S. will deny visas to travel to the U.S. for persons who meet the
above criteria, as well as revoke the visas of such persons already in the United States.
The bill also contains a number of non-sanctions provisions, including: authorizing $50 million to improve
democracy and governance in Eastern and Central Europe; authorizing $100 million for increased security
cooperation in the region; and providing for U.S. assistance in recovering Ukrainian state assets allegedly stolen
by former Ukrainian President Viktor Yanukovych and his former officials.
3. PattonBoggs.com Client Alert: Crimea: U.S. Response Intensifies 3
In conjunction with H.R. 4152, both chambers of Congress also passed an act authorizing United States
International Programming to Ukraine and Neighboring Regions (S. 2183), which authorizes the appropriation
of $10 million to fund Ukrainian, Russian, and Tatar language broadcasts on U.S. public diplomacy channels to
counter perceived Russian propaganda. This is a priority issue for House Foreign Affairs Committee Chairman
Ed Royce (R-California).
ANALYSIS OF RECENT EXECUTIVE BRANCH ACTION
Executive Order 13662
On March 20, President Obama signed a third Executive Order (E.O. 13662), which authorizes the imposition
of sanctions against additional categories of persons who operate in sectors of the Russian Federation economy,
such as the financial services, energy, metals and mining, engineering, and defense and related materiel
industries. To date, no individuals or entities have been sanctioned pursuant to E.O. 13662, although this
measure is designed to serve notice to broad sectors of the Russian economy that they may be targeted in the
future.
In particular, E.O. 13662 authorizes the imposition of sanctions against the following three categories of
persons:
→ Persons who operate in sectors of the Russian Federation economy that have been the subject of a
joint U.S. Treasury and Department of State “determination,” (such as financial services, energy, metals
and mining, engineering, and defense and related material industries);
→ Persons who materially assist, sponsor, or provide financial, material, or technological support for, or
goods or services to or in support of a senior official in the Government of the Russian Federation or a
person designated pursuant to the new E.O; or
→ Persons directly or indirectly owned or controlled by, or acting for or on behalf of, a senior official in
the Government of the Russian Federation or a person designated pursuant to the new E.O.
The E.O. authorizes the same sanctions – asset freezes and visa bans – as the Congressional legislation.
Notably, it authorizes the imposition of sanctions against persons who operate in “such sectors of the Russian
Federation economy as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State, such as
financial services, energy, metals and mining, engineering, and defense and related materials.” (emphasis added).
This indicates that the U.S. government views the list of industry sectors as an illustrative non-exhaustive list,
and the U.S. Treasury and State Departments have authority to determine that additional sectors of the Russian
economy should be targeted in the future. E.O. 13662 is silent, however, as to the criteria that should be
applied in making these determinations.
4. PattonBoggs.com Client Alert: Crimea: U.S. Response Intensifies 4
It is significant that the new E.O. authorizes sanctions against persons who operate in these sectors of the
Russian economy, but does not immediately impose sanctions on them for doing so. In addition to determining
the economic sectors to be targeted, the E.O. requires the U.S. Treasury, in consultation with the U.S.
Department of State, to then determine that a the person operates in one of these sectors of the Russian
Federation economy. Presumably, a person will be sanctioned only after both determinations have been made.
The U.S. government has wide discretion in making these determinations.
In our view, the Obama administration issued this E.O. in part to get out ahead of Congress as a means of
discouraging Congress from adopting further legislation in the near term, especially legislation that could go
beyond the level of sanctions that the President considers appropriate under the circumstances or that would
otherwise interfere with the Obama administration's diplomatic negotiations to advance the national interest.
Moreover, by issuing the E.O. prospectively, the Obama administration signaled clearly that it is prepared to
impose sanctions on sectors that could have a significant impact on the Russian economy.
ADDITIONAL DESIGNATIONS UNDER E.O. 13661
On March 20, the Treasury Department’s Office of Foreign Assets Control (OFAC) designated sixteen senior
Russian government officials, four Russian business leaders described by the U.S. Treasury as members of
Russian President Vladimir Putin’s “inner circle,” and one Russian bank pursuant to E.O. 13661. E.O. 13661
authorizes the imposition of sanctions against senior Russian government officials, as well as those determined
to be “acting for or on behalf of or materially assisting, sponsoring, or providing financial, material, or
technological support for, or goods or services to or in support of, a senior Russian government official.” The
U.S. government determined that the four Russian business leaders and one Russia bank are each controlled by,
acting for or on behalf of, or providing material or other support to, a senior Russian government officials. (For
more information on E.O. 13661, see Patton Boggs’ Client Alert here.)
These designations are in addition to sanctions imposed against seven Russian persons and four Ukrainian
persons pursuant to E.O. 13660 on March 6. (For more information on E.O. 13660, see Patton Boggs Client
Alert here.) The complete Specially Designated Nationals and Blocked Persons List is available here.
ADMINISTRATIVE LICENSING FREEZE
The Bureau of Industry and Security (U.S. Department of Commerce) disclosed that beginning March 1 it
placed a hold on all applications for licenses to export items from the U.S. to Russia until further notice. In
2013, the Bureau approved over 1,800 applications to export “dual use” items to Russia – worth $1.5 billion.
The Directorate of Defense Trade Controls (U.S. Department of State) also announced that it has stopped
processing applications for licenses to export “defense articles and defense services” to Russia until further
notice. U.S. industry has expressed concern that these policies will only hurt U.S. businesses because they need
export licenses to ship their products to Russia. Russian companies are still able to procure these items from
manufacturers in other countries.
5. PattonBoggs.com Client Alert: Crimea: U.S. Response Intensifies 5
POTENTIAL FURTHER DEVELOPMENTS
Both the White House and Congress have indicated that they may impose further sanctions against the Russian
Federation depending on how the situation in Ukraine continues to develop. During his trip to Europe last
week, President Obama suggested that the United States and its allies will hold off on implementing additional
economic sanctions, but indicated that this may change if the situation in Ukraine deteriorates. His statement
does not preclude sanctioning more individuals and entities under existing sanctions authorities.
In the near term, we do not expect Congress to pass additional sanctions legislation, as long as the President
remains out front on the issue and developments in the region do not change materially. That said, the risk
remains high that, for political and other reasons, members of Congress will continue to push for additional
sanctions. Thus, the risk remains high that the White House will be forced to impose additional sanctions to
head off legislation or will be forced by events to negotiate with Congress over an acceptable range of
additional measures to be imposed by statute.
Moreover, the G-7 countries, the White House, and Congress also agree that further sanctions would be
warranted if Russia takes additional actions, such as invading eastern or southern Ukraine or the Transnistria
region of Moldova, or interfering in the May 25 Ukrainian presidential election. In the March 31 White House
Press Briefing, Press Secretary Carney stated the White House’s position that: “there will be potentially more,
and more serious consequences imposed by the United States and our partners, should Russia engage in further
acts that violate Ukraine’s territorial integrity and sovereignty.”
By all indications, this is still a very fluid situation. Companies should examine the nature and extent of any
business operations in Russia and/or Ukraine to understand their potential exposure under these sanctions
measures. For advice on specific transactions related to Russia and/or Ukraine, please contact Joseph L. Brand
(jbrand@pattonboggs.com), Stephen J. McHale (smchale@pattonboggs.com), or Daniel E. Waltz
(dwaltz@pattonboggs.com).