During this practical opening session, Fenwick trade & national security partner Rob Slack will talk through the key agencies involved in U.S. sanctions implementation and enforcement and discuss the evolving framework of U.S. Secondary Sanctions and Human Rights-related actions including:
- Basics of sanctions law: e.g., TWEA, IEEPA, Executive Orders, and Designations
- Introduction to OFAC, BIS, DOJ, State Department, Congress and how they work together
- U.S. Sanctions Jurisdiction: Extra-Territoriality
- What are Primary, Sectoral, and Secondary Sanctions?
- Introduction to OFAC’s 50% Rule
- Key Licenses and Exemptions
- Sources of Guidance: Alerts, FAQs, and Enforcement Actions
Enforcement and Secondary Sanctions
- Enforcement framework and penalty exposure
- Scope: Menu-based versus Designations
- Application in Practice
- Financial Institution Considerations
Intersection of Economic Sanctions, Export Controls and other National Security Rules
- Russia & Belarus case study: sanctions, export controls, tariffs and more
- Human Rights: Import controls, export controls and sanctions to target human rights violations and abuses