Reed Smith Monday, July 18, 2011

Alert 11-167

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Sanctions Targets

 

 

The last eighteen months have seen numerous new sanctions regimes introduced by the EU, UN and the U.S. Reed Smith has issued a series of Client Alerts already this year as and when new or changed sanctions regimes have been introduced. Amongst the energy and commodity trading and the shipping communities, there has naturally been a heavy focus on Iranian, Ivory Coast and Libyan sanctions. It is important to understand, however, that there are now a whole host of countries facing sanctions from the EU, UN and U.S. Whilst the sanctions position is fast moving, we thought it sensible to draw all of these together in one place. 

 

The foundations of EU sanctions regimes are the lists of "designated persons". Those subject to the EU Regulations cannot make funds or economic resources directly or indirectly available to or for the benefit of designated persons, who are also subject to an asset freeze. The U.S. has also frequently updated its list of Specially Designated Nationals ("SDNs"). "U.S. persons" and non-U.S. financial institutions should not have any dealings with SDNs. "U.S. persons" is defined as U.S. citizens, permanent resident aliens, persons physically in the U.S., U.S. organised entities and foreign branches. Of course, even if not a "U.S. person", many entities take the view that they should not in any event have business dealings with SDNs.


The attached table identifies the various sanctions regimes and includes links to the relevant list of "designated persons" for that country.


It is, of course, the fact that the sanctions often go beyond the targeting of specific entities and individuals to focus also on particular sectors and activities.

 

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Sanctions Regimes

 



Reed Smith further expands its Energy & Natural Resources Group
with new Partner
Patty Dondanville


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Reed Smith is pleased to announce the addition of partner Patty Dondanville to its Energy & Natural Resources Group, based in our Chicago office. Patty advises energy companies (including electric and natural gas utilities, electric cooperatives and government-owned utilities) in connection with their acquisition, divestiture and financing of infrastructure assets, and on the legal, credit, regulatory and operational risks associated with energy marketing, energy supply and derivatives trading. Patty structures, documents and negotiates physical commodity and derivative master trading agreements, credit support arrangements and liquidity facilities, including lien-based collateral programs for energy market participants. More than a decade ago, at the request of the Edison Electric Institute and the National Energy Marketing Association , Patty co-chaired an electricity industry-wide committee and drafted a standardised master contract for the purchase and sale of wholesale electric power in the United States. The committee also assisted ISDA in drafting its North American Power Annex. Patty also provides legislative and regulatory policy advice both to energy companies and to energy trade associations, and has recently been involved in analysing the derivatives legislation that became Title VII of the Dodd-Frank Act. Her arrival will strengthen further the expertise we are able to offer Reed Smith's energy clients in the US, and will complement the practices of John Varholy, Brett Hillis, Jacqui Hatfield and their teams in EME. Patty's arrival brings to nine the number of partners to join Reed Smith's Energy & Natural Resources Group in the past year. 

 

 

'Sanctions Targets' Author:   Advice on U.S. Sanctions:  
  

Mark Church

Associate
London

+44 (0)20 3116 3402

 


Leigh T. Hansson
Partner
Washington, D.C.

+1 202 414 9394


Matthew J. Thomas
Partner
Washington, D.C.
+1 202 414 9257


 

 

ETC Partners:
  

Suzanne Bainbridge
Partner
London

+44 (0)20 3116 2815

 

Gordon Bell
Partner
London

+44 (0)20 3116 3765

Peter Cassidy

Partner
London

+44 (0)20 3116 3697

Paul Dillon
Partner
London

+44 (0)20 3116 2893

Kyri Evagora
Partner
London

+44 (0)20 3116 2914

 

Siân Fellows
Partner
London
+44 (0)20 3116 2809

Diane Galloway
Partner
London

+44 (0)20 3116 2934

 

Keith Hartley

Partner
London

+44 (0)20 3116 3694

 

Brett Hillis

Partner
London

+44 (0)20 3116 2992

Robert Parson
Partner
London

+44 (0)20 3116 3514

 

Vincent Rowan

Partner
London

+44 (0)20 3116 3772

Stefan Schmitz
Partner
London
+44 (0)20 3116 3760

Richard Swinburn
Partner
London
+44 (0)20 3116 2933

John Varholy

Partner
London

+44 (0)20 3116 2933

Shai Wade
Partner
London

+44 (0)20 3116 3620

 

 

 

 


 

ReedSmith
About Reed Smith
Reed Smith is a global relationship law firm with more than 1,600 lawyers in 23 offices throughout the United States, Europe, Asia and the Middle East. Founded in 1877, the firm represents leading international businesses, from Fortune 100 corporations to mid-market and emerging enterprises. Its lawyers provide litigation and other dispute resolution services in multi-jurisdictional and other high-stakes matters; deliver regulatory counsel; and execute the full range of strategic domestic and cross-border transactions. Reed Smith is a preeminent advisor to industries including financial services, life sciences, health care, advertising, technology and media, shipping, energy trade and commodities, real estate, manufacturing, and education. For more information, visit reedsmith.com.

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The information contained in this Client Alert is intended to be a general guide only and not to be comprehensive, nor to provide legal advice. You should not rely on the information contained in this Alert as if it were legal or other professional advice.

Reed Smith LLP is a limited liability partnership registered in England and Wales with registered number OC303620 and its registered office at The Broadgate Tower, 20 Primrose Street, London EC2A 2RS. Reed Smith LLP is regulated by the Solicitors Regulation Authority. Any reference to the term 'partner' in connection to Reed Smith LLP is a reference to a member of it or an employee of equivalent status.

This Client Alert was compiled up to and including July 2011.

The business carried on from offices in the United States and Germany is carried on by Reed Smith LLP of Delaware, USA; from the other offices is carried on by Reed Smith LLP of England; but in Hong Kong, the business is carried on by Richards Butler in association with Reed Smith LLP (of Delaware, USA), and in Beijing, by Reed Smith Richards Butler LLP. A list of all Partners and employed attorneys as well as their court admissions can be inspected at the firm's website.


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