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44 Geo. J. Int'l L. 1055 (2012-2013)
Sanctions, Sanctions Everywhere: Forging a Path through Complex Transnational Sanctions Laws

handle is hein.journals/geojintl44 and id is 1083 raw text is: SANCTIONS, SANCTIONS EVERYWHERE: FORGING A PATH THROUGH COMPLEX TRANSNATIONAL SANCTIONS LAWS MEREDITH RATHBONE,* PETERJEYDEL,t AND AMY LENTZ+ ABSTRACT Compliance with the web of economic sanctions laws that have proliferated over the past two decades, and which have grown far more complex still over the last few years, is an increasingly critical challenge facing many transnational businesses. These measures often reach beyond the territory of the jurisdiction that enacted them and regulate activities and entities throughout the world. Com- pounding the difficulty of complying with these laws, companies may find differing provisions and even conflicts among the varied regimes of the major jurisdictions that have put significant economic sanctions programs into effect. Moreover, countries are increasingly experimenting with novel ways of restricting the types of commerce that they seek to control. This Article provides a roadmap through the thicket that has grown around this area of law. TABLE OF CONTENTS 1. INTRODUCTION.................................... 1056 11. BACKGROUND...................................... 1057 A. Overview of Sanctions ........................... 1057 B. General History of Sanctions....................... 1063 III. OVERVIEW OF THE SANCTIONS REGIMES FOR CUBA, IRAN, SUDAN, AND SYRIA........................................ 1075 A . Cuba ....................................... 1075 B . Iran ........................................ 1081 C . Sudan ...................................... 1093 D. Syria ....................................... 1094 IV. COMPLIANCE CHALLENGES CONFRONTING BOTH U.S.-BASED AND FOREIGN MULTINATIONAL COMPANIES IN RELATION TO THE U.S. ECONOMIC SANCTIONS REGIMES . ........................ 1095 * Meredith Rathbone is a partner in the Washington, D.C. office of Steptoe &Johnson LLP, where she is a member of the firm's International Department. She regularly counsels clients on sanctions and export controls compliance and enforcement matters. t PeterJeydel is an associate in the Washington, D.C. office of Steptoe &Johnson LLP, where he is a member of the firm's International Department. Amy Lentz is an associate in the Washington, D.C. office of Steptoe &Johnson LLP, where she is a member of the firm's International Department. @ 2013, Meredith Rathbone, PeterJeydel, and Amy Lentz. 1055