US Sanctions

Sanctions Compliance Beyond the 50% Rule: A Practical Guide for Indian Businesses

Summary: The 50% ownership rule has always been the cornerstone of sanctions compliance offering apparent certainty to entities navigating complex cross-border transactions. However, in recent years, global regulators have started looking beyond the ownership percentage, scrutinizing effective control and influence to determine sanctions exposure. This piece examines the evolving sanctions landscape across the US, UK & EU and provides Indian businesses with a practical, risk-based compliance framework to align with international enforcement expectations.

Continue Reading Sanctions Compliance Beyond the 50% Rule: A Practical Guide for Indian Businesses
US-India discussion on Sanctions: Indian Companies to remain diligent about Sanctions Compliance

Recent actions: Russia-related sanctions

On October 30, 2024, the United States (“US”) Department of Treasury’s Office of Foreign Asset Control (“OFAC”) sanctioned 19 Indian companies and 2 Indian individuals under its Russia-related sanctions program under the Executive Order (“EO”) 14024. This action was in the nature of imposition of secondary sanctions on third-country actors to discourage non-US persons from engaging in certain transactions, even without a US nexus, that might be harmful to the objectives of the US sanctions programs.

Continue Reading US-India discussion on Sanctions: Indian Companies to remain diligent about Sanctions Compliance
Ripple Effect of Sanctions- II: Recent Iran-related sanctions imposed by the United States

Background

In the previous blog published on November 19, 2024, we had discussed the United States (“US”) Office of foreign Asset Control (“OFAC”) sanctioning nearly 400 entities and individuals for their contribution to Russia’s efforts against Ukraine and the implications of this action on Indian businesses. The US has since imposed sanctions on several entities under its Russia-related sanctions program as well as under its other sanctions programs. There has also been a major focus on the Iran-related sanctions program.

Continue Reading Ripple Effect of Sanctions- II: Recent Iran-related sanctions imposed by the United States
The Turning Tides of US Sanctions: India Caught in the Middle

Secondary Sanctions & Countermeasures

The recent escalation of United States (“US”) sanctions against Russia seems to have significant consequences for the Indian market. India has strong economic relationships with both the countries. At the moment, however, India seems to be caught between a ‘rock and a hard place’.[1] The country finds itself in a tricky minefield and it has to now balance its financial interests, along with its obligations to the international community.

Continue Reading The Turning Tides of US Sanctions: India Caught in the Middle