global economic sanctions year-end summary · global economic sanctions year-end summary 22 january...
TRANSCRIPT
1
Global Economic Sanctions Year-End Summary 22 January 2020
2019 saw significant economic sanctions developments in the United States and Europe. The United States expanded a number of its sanctions programs and engaged in an unprecedented level of enforcement. In turn, European, Canadian, and other governments have wrestled with ways to protect their citizens and companies from the extra-territorial effect of some U.S. sanctions while also implementing new sanctions of their own. Below are highlights surveying the sanctions landscape in 2019.
1. Highlights of U.S. sanctions risks facing global companies
1.1. Cuba: Title III of the Helms-Burton Act activated
In 1996, the United States enacted the Cuban Liberty and Democratic
Solidarity (Libertad) Act of 1996, also known as the Helms-Burton Act (the
“Act”).1 Among the Act’s more controversial provisions is Title III, which
allows U.S. nationals to sue in U.S. courts any individual or entity who
“traffics”2 in (i.e., uses) property that was confiscated by the Cuban
government on or after 1 January 1959. That provision was immediately
suspended by President Clinton, however, and it remained suspended
throughout successive administrations and was without effect.
But the executive branch changed course in April 2019, when the U.S.
Secretary of State announced that the suspension of Title III would lapse on
2 May 2019. Now that the private right of action is available, companies
around the world with activities in Cuba face the potential for litigation in U.S.
courts by those whose property was confiscated by the Cuban government
between 1959 and 1996. A limited number of plaintiffs have now filed
lawsuits under Title III that will be watched closely by the market and
sanctions practitioners as they work their way through the courts.3
Even when the private right of action was suspended, it was advisable for
companies operating in Cuba to conduct diligence on property involved, and
to proactively reach settlements with potential U.S. claimants when property
1 22 U.S.C. §§ 6021-6091.
2 See 22 U.S.C. § 6023(13)(A) (defining “traffics” broadly).
3 Of note, while there are as many as 6,000 estimated “certified claims” for confiscated property arising
under the Title III private right of action, only 22 lawsuits had been filed in U.S. courts to date.
Contents
Contents 1. Highlights of U.S. sanctions risks facing
global companies 1 2. Other developments in U.S. sanctions 6 3. Other developments in EU sanctions 8 Key contacts 9
2
was identified as having been confiscated. The need for careful diligence is
now greater than ever in connection with activities involving Cuban property.
EU Response. In 1996, in response to the Helms-Burton Act, the EU
created the EU Blocking Regulation to protect persons and entities under EU
jurisdiction (“EU Operators”) against the extra-territorial effect of the U.S.
sanctions targeting Cuba as mentioned above. In essence, the EU Blocking
Regulation nullifies the effect in the EU of U.S. court rulings based on these
sanctions and allows EU Operators to recover damages arising therefrom.
Furthermore, the EU Blocking Regulation prohibits EU Operators from
complying with such extra-territorial sanctions.
As the United States continued to suspend the application of Title III of the
Helms-Burton Act, there was no need to enforce the EU Blocking
Regulation. However, further to the full activation of the Helms-Burton Act,
the EU announced that it is now considering actively using the EU Blocking
Regulation in relation to the sanctions targeting Cuba.
It remains to be seen how damages claims pursuant to the Helms-Burton
Act will unfold in the United States in the coming months and how the EU
and its Member States will react to specific enforcement cases.
1.2. Iran: expansion of secondary sanctions
Following its withdrawal from the nuclear deal (the “Joint Comprehensive
Plan of Action” or “JCPOA”4) and reimposition of sanctions on Iran in 2018,
the United States has continued its “maximum pressure” campaign against
Iran. So-called “secondary” sanctions that are designed to target non-U.S.
persons engaged in activities with no U.S. nexus continue to expand.5 For
example, in 2019, the United States announced new secondary sanctions
for any persons who engage in significant dealings involving Iran’s iron,
copper, aluminium, and steel industries.6 The United States also issued only
one round of Significant Reduction Exceptions for certain countries to
purchase Iranian oil, to allow those purchases to wind-down, and has
sanctioned non-U.S. entities that have continued to support Iranian oil
sales.7
4 The JCPOA is a multilateral agreement that was originally concluded between Iran, the United States, the
United Kingdom, France, Germany, Russia, China, and the EU. The agreement aims to stop and prevent
Iran from producing nuclear weapons. In exchange for Iran complying with its commitments under the
JCPOA, the then existing UN sanctions and the most economically damaging nuclear-related sanctions by
the EU and the United States were either lifted or suspended on 16 January 2016.
5 For a high-level discussion on many of these secondary sanctions that the United States imposed
following its withdrawal from the JCPOA, see OFAC’s “Frequently Asked Questions Regarding the Re-
Imposition of Sanctions Pursuant to the May 8, 2018 National Security Memorandum Relating to the Joint
Comprehensive Plan of Action (JCPOA)” (6 August 2018), available at www.treasury.gov/resource-
center/sanctions/Programs/Documents/jcpoa_winddown_faqs.pdf.
6 Executive Order 13871, “Imposing Sanctions With Respect to the Iron, Steel, Aluminium, and Copper
Sectors of Iran” (8 May 2019), available at www.treasury.gov/resource-
center/sanctions/Programs/Documents/13871.pdf.
Notably, on 10 January 2020, the United States sanctioned Iran’s 13 largest steel and iron manufacturers,
including Mobarakeh Steel Company, the biggest steel producer in the Middle East. See U.S. Department
of the Treasury, “Treasury Targets Iran’s Billion Dollar Metals Industry and Senior Regime Officials” (10
January 2020), available at https://home.treasury.gov/news/press-releases/sm870.
7 For example, in September 2019, the United States imposed sanctions under section 3 of Executive
Order 13846 on six Chinese firms, including two subsidiaries of state-owned COSCO Shipping
Corporation Ltd., for knowingly transporting Iranian oil. See Executive Order 13846, “Reimposing Certain
3
While a number of sectors in Iran remain sanctions free (for non-U.S.
persons), such as the consumer goods, medical, and agricultural sectors,
the risk of dealings in Iran triggering secondary sanctions continues to rise.8
Diplomatic relations between the United States and Iran continue to decline,
and we do not expect these sanctions to abate in the near future.
Accordingly, non-U.S. companies operating in Iran must remain vigilant to
understand whether their activities may trigger secondary sanctions while
simultaneously observing their sometimes-contradictory obligations under
EU law.
EU’s Position. In response to the toughening of the U.S. sanctions against
Iran, Iran has, amongst others, reduced its commitment to the JCPOA.
Notwithstanding Iran’s violations of the nuclear deal, the EU has continued
the sanctions lifting agreed under the deal. The EU has however demanded
that Iran immediately stop taking steps away from the nuclear deal. On 14
January 2020, the United Kingdom, France and Germany jointly triggered
the dispute resolution mechanism set forth in the JCPOA to hold Iran to
account for its non-compliance. Iran’s continued violations of the nuclear
deal and a further escalation of its conflict with the United States could
culminate in the return of the comprehensive UN and EU sanctions against
Iran that have remained lifted in a matter of weeks, i.e., the so-called
“sanctions snapback”.9
1.3. Russia: maintaining the pressure
Tensions between the United States and Russia remain high, and additional
(albeit limited) sanctions have been imposed with respect to Russia in 2019:
Russian Energy Export Pipelines – In December 2019, the United
States enacted the “Protecting Europe’s Energy Security Act of 2019,”10
which purports to require the President to impose secondary sanctions
against pipe-laying vessels and their owners involved in the construction
of the Nord Stream 2 and TurkStream pipelines, and successor projects.
Those sanctions have not yet been implemented.
Chemical and Biological Weapons (“CBW”) Act – In August 2019,
the United States imposed sanctions on Russia under the CBW Act in
response to Russia’s use of a nerve agent in the United Kingdom in
March 2018. The sanctions prohibit U.S. banks both from participating in
Sanctions With Respect to Iran” (6 August 2018), available at www.treasury.gov/resource-
center/sanctions/Programs/Documents/13846.pdf.
8 Indeed, companies operating even in those sectors must still be mindful of sanctions for transacting with
sanctioned persons or entities, causing violations by U.S. persons including U.S financial institutions, or
other collateral triggers that may not be obvious on the face of their business.
The trend of increasing secondary sanctions continued into 2020 when President Trump issued a new
executive order authorising blocking sanctions on any person that is in, or engages in significant
transactions with or in support of, Iran’s mining, construction, manufacturing, or textiles sectors. For more
information, see Linklaters’ client alert “United States Imposes New Sanctions on Iran’s Construction,
Mining, Manufacturing, and Textile Sectors (10 January 2020), available at
www.linklaters.com/en/insights/publications/us-publications/2020/january/united-states-imposes-new-
sanctions-on-irans-construction-mining-manufacturing-and-textile-sectors.
9 For more information in relation to the sanctions snapback, see Linklaters’ client alert “Could sanctions
against Iran be reintroduced?”, available at www.linklaters.com/en/insights/publications/2019/july/could-
sanctions-against-iran-be-reintroduced.
10 See Title LXXV of the National Defense Authorization Act for the Fiscal Year 2020, available at
www.congress.gov/bill/116th-congress/house-bill/2500/text.
4
the primary market for non-ruble denominated bonds issued by Russia
and from lending non-ruble denominated funds to Russia; create a
presumption of denial (subject to exceptions) for license applications
relating to dual-use goods controlled by the Department of Commerce
for chemical and biological weapons proliferation reasons; and require
the United States to oppose loan and financial or technical assistance by
international financial institutions. While the new sanctions could have
been more severe, they allow the administration to demonstrate
compliance with its statutory obligation to impose CBW sanctions.
DASKA – Support exists in Congress for the imposition of additional
sanctions on Russia, and a number of bills were introduced in 2019 to
accomplish that goal. For example, one bill – the Defending American
Security From Kremlin Aggression Act of 2019 (“DASKA”) – would
impose wide-ranging sanctions on Russia for interfering in the 2016 U.S.
presidential election, including by targeting Russia’s energy sector,
banking sector, and its sovereign debt. We cannot predict whether any
particular bill will ultimately be enacted into law, but DASKA has
received considerable attention and bipartisan support in Congress.
1.4. Venezuela: escalation of pressure
OFAC has also sought to place further economic pressure on Venezuela in
2019 in the hopes of driving President Maduro from power. On 5 August
2019, the President issued Executive Order 13884, “blocking” all
Venezuelan government entities and state-owned enterprises. If property in
which any such entity has any interest whatsoever comes into the
possession or control of a U.S. person, it must be “blocked” (frozen), and
U.S. persons are generally prohibited from engaging in transactions with the
entity.11 However, OFAC has issued a range of general licenses to soften
the impact of Executive Order 13884, and the other Executive Orders
targeting Venezuela.
The United States has also been aggressive in imposing secondary
sanctions on non-U.S. companies that engage in significant dealings in the
Venezuelan oil industry or that arguably support the Maduro regime. For
example:
In March 2019, the United States sanctioned Evrofinance Mosnarbank –
which is jointly-owned by Russian and Venezuelan state-owned
companies – for attempting to help the Maduro regime avoid sanctions
against the state-owned oil company Petroleos de Venezuela S.A.12
In April 2019, the United States sanctioned Liberian companies Jennifer
Navigation Ltd., Lima Shipping Corp. and Large Range Ltd., and the
11 Executive Order 13884, “Blocking Property of the Government of Venezuela” (5 August 2019), available at
www.treasury.gov/resource-center/sanctions/Programs/Documents/13884.pdf.
12 U.S. Department of the Treasury, “Treasury Sanctions Russia-based Bank Attempting to Circumvent U.S.
Sanctions on Venezuela” (11 March 2019), available at https://home.treasury.gov/news/press-
releases/sm622.
5
Italian shipping company PB Tankers S.P.A. for transporting oil from
Venezuela to Cuba.13
What the United States may have initially intended to be short-term
sanctions meant to help drive Maduro from power have not yet led to regime
change. It remains to be seen what, if any, additional sanctions the United
States may impose to further pressure Maduro to step down.
1.5. EU response to U.S. sanctions programs updates
On principle, the EU opposes secondary sanctions on EU Operators. For
instance, the EU denounced the secondary sanctions in relation to the
construction of the Nord Stream 2 pipeline mentioned above.
The recently elected President of the EU Commission, Ursula von der
Leyen, furthermore announced that she intends to develop proposals to
ensure Europe is more resilient to secondary sanctions. Accordingly, it is
possible that the scope of the EU Blocking Regulation, which currently
already covers a number of U.S. secondary sanctions against Cuba and
Iran, will be expanded to cover other U.S. sanctions with an extra-territorial
effect.14 This means that EU Operators would enjoy protection against an
increased number of U.S. secondary sanctions under the EU Blocking
Regulation. They would, however, at the same time, also be prohibited from
complying with an increased number of U.S. secondary sanctions.
The reality of many EU Operators with global activities is, nevertheless, that
they are strongly connected to the United States, whether in terms of access
to the U.S. market or the U.S. financial system. For these EU Operators a
further expansion of the scope of the EU Blocking Regulation to other U.S.
sanctions programs will add legal complexity and challenges. Furthermore,
the question remains whether the EU Blocking Regulation offers sufficient
protection against the exposure to U.S. secondary sanctions for these EU
Operators.
Another complexity is that the EU Member States are themselves
responsible for the implementation and enforcement of the EU Blocking
Regulation, including for sanctioning possible breaches thereof. The nature
and level of the penalties (e.g., prison term and/or criminal fines, or only
administrative/regulatory penalties) thus vary from EU Member State to EU
Member State, and EU Operators will also need to consider these
differences in implementation and enforcement.
While a number of EU Member States have implemented the EU Blocking
Regulation many years ago, or have recently amended or enacted
implementing legislation, a small number of EU Member States, including
France, still have not implemented any penalties.15 These remaining
Member States may, in light of the EU Commission‘s intention to increase
13 U.S. Department of the Treasury, “Treasury Increases Pressure on Cuba to End Support to Maduro by
Imposing Further Oil Sector Sanctions” (12 April 2019), available at https://home.treasury.gov/news/press-
releases/sm653.
14 For more information, see Linklaters’ client alert “Belgium implements EU Blocking Regulation”, available
at www.linklaters.com/en/insights/publications/2019/may/belgium-implements-eu-blocking-regulation.
15 For more information, see Linklaters’ client alert “Belgium implements EU Blocking Regulation”, available
at www.linklaters.com/en/insights/publications/2019/may/belgium-implements-eu-blocking-regulation.
6
the EU’s resilience against secondary sanctions, in the near future be urged
to adopt implementing legislation and issue penalties.
2. Other developments in U.S. sanctions
In addition to the country-specific U.S. sanctions developments detailed
above, 2019 saw significant developments to the U.S. sanctions landscape
more generally.
2.1. Active enforcement by OFAC
There was a marked increase in OFAC enforcement in 2019, with 26 civil
penalties announced, amounting to $1,289,027,059 in penalties and
settlements, compared to seven civil penalties and $71,510,561 in penalties
in all of 2018.16 OFAC’s enforcement actions included a number of firsts last
year. Notably, OFAC brought its first enforcement action based on a
violation of U.S. sectoral sanctions in Russia.17 OFAC also designated third-
country shipping companies (and their vessels) for transporting Venezuelan
and Iranian oil, demonstrating a continued emphasis on sanctions risk in the
shipping18 and petroleum industries as well as a potential sign of increased
use of secondary sanctions authorities.19
2.2. Compliance guidance
Alongside its uptick in enforcement, OFAC published “A Framework for
OFAC Compliance Commitments” (the “Framework”) in May 2019, setting
out not only the five essential components of an effective U.S. sanctions
compliance program, but also helpfully identifying the most prominent “root
causes” of recent sanctions violations.20 The Framework followed months of
focus by OFAC (communicated through its increased enforcement activity)
on the importance of designing, implementing, and maintaining sound
compliance practices. This guidance can serve as a useful blueprint for
global companies considering the sufficiency of their sanctions compliance
programs.21
16 OFAC, Civil Penalties and Enforcement Information, available at www.treasury.gov/resource-
center/sanctions/CivPen/Pages/civpen-index2.aspx.
17 OFAC, Enforcement Information for April 25, 2019, available at www.treasury.gov/resource-
center/sanctions/CivPen/Documents/20190425_haverly.pdf.
18 OFAC has written extensively on the sanctions risks associated with the shipping industry, including in
relation to shipping petroleum and petroleum products to Iran. See, e.g., OFAC Advisory to the Maritime
Petroleum Shipping Community (4 September 2019), available at www.treasury.gov/resource-
center/sanctions/Programs/Documents/iran_advisory_09032019.pdf.
19 OFAC followed those designations in early 2020 by designating a number of Chinese entities under its
secondary sanctions authority for knowingly engaging in significant transactions involving Iran’s metals
sectors under Executive Order 13871. See OFAC announcement, “Treasury Targets Iran’s Billion Dollar
Metals Industry and Senior Regime Officials,” (10 January 2020) available at
https://home.treasury.gov/news/press-releases/sm870.
20 OFAC, A Framework for OFAC Compliance Commitments (2 May 2019), available at
www.treasury.gov/resource-center/sanctions/Documents/framework_ofac_cc.pdf.
21 For more information on the compliance guidance, see Linklaters’ alert “OFAC publishes sanctions
compliance guidance and identifies root causes of violations” (8 May 2019), available at
www.linklaters.com/en/insights/blogs/businesscrimelinks/2019/may/ofac-publishes-sanctions-compliance-
guidance-and-identifies-root-causes-of-violations. For more on how OFAC signals the importance of
compliance through its enforcement activity, see an article published by Linklaters in the International
Financial Law Review, “OFAC provides guidance through enforcement” (26 February 2019), available at
www.iflr.com/Article/3860483/Leading-by-example.html?ArticleId=3860483.
7
2.3. Sanctions enforcement by other regulators
In addition to robust enforcement by OFAC, 2019 also saw an increase in
attention to sanctions by other enforcement agencies like the SEC. Notably,
in September 2019, the SEC issued an order settling claims against a U.S.
issuer based on, among other things, its failure to implement adequate
internal accounting controls to prevent bribery and violations of U.S.
sanctions.22 This order is important as it may signal a new trend in using the
SEC’s books-and-records and internal controls provisions as a tool for
enforcement against public companies.
2.4. High diligence and monitoring expectations
OFAC’s enforcement actions in 2019 also serve as a warning to market
participants that it has high expectations when it comes to diligence and
controls. For example:
In one enforcement action, OFAC found that a U.S. company violated
sanctions by leasing aircraft engines to a UAE-based lessee under an
agreement that explicitly prohibited the lessee from using the engines in
relation to any countries subject to U.S. sanctions.23 The UAE lessee
nevertheless installed the engines on a Ukrainian sublessee’s aircraft, which
were in turn leased to the sanctioned Sudan Airways (this was before U.S.
sanctions on Sudan were lifted) and flown to and from Sudan. When the
U.S. company learned how its engines were being used, it immediately
demanded that one outstanding engine be returned and self-reported to
OFAC.
In its announcement OFAC concluded that the U.S. company failed to
“ensure” its engines “were utilized in a manner that complied with OFAC’s
regulations.” OFAC noted, for example, that the company “did not obtain
U.S. law export compliance certificates from lessees and sublessees” and
the company “did not periodically monitor or otherwise verify its lessee’s and
sublessee’s adherence to the lease provision requiring compliance with U.S.
sanctions during the life of the lease.”
This action serves as a helpful reminder of the strict-liability nature of
sanctions violations for U.S. persons and that the inclusion of appropriate
provisions in agreements with counterparties is only one step towards an
effective compliance program.
22 SEC Press Release, “SEC Charges Marketing and Printing Services Provider with FCPA Violations” (26
September 2019), available at www.sec.gov/news/press-release/2019-193.
23 OFAC, Enforcement Information for November 7, 2019, available at www.treasury.gov/resource-
center/sanctions/CivPen/Documents/20191107_apollo.pdf.
8
3. Other developments in EU sanctions
In the course of 2019, the EU adopted three new sanctions programs:
3.1. Sanctions against cyber-attacks
This new sanctions program (Council Regulation 2019/79624) establishes a
framework which allows the EU to impose restrictive measures to deter and
respond to (attempted) cyber-attacks which constitute an external threat to
the EU or its member states, including cyber-attacks against third states or
international organisations. The sanctions target persons or entities directly
or indirectly responsible for (attempted) cyber-attacks or having financed or
assisted with such cyber-attacks. These persons or entities do not need to
be linked to one or another country.
Potential sanctions include a travel ban and the freezing of funds and
economic resources of the persons or entities listed under the sanctions
program. EU persons and entities are also prohibited from making funds
available to these sanctioned persons or entities.
3.2. Sanctions against Nicaragua
This new sanctions program (Council Regulation 2019/171625) allows for
sanctions to be imposed on persons and entities responsible for human
rights violations or abuses or for the repression of civil society and
democratic opposition in Nicaragua, as well as persons and entities whose
actions, policies or activities otherwise undermine democracy and the rule of
law in Nicaragua.
Potential sanctions include a travel ban and the freezing of funds and
economic resources of the persons or entities listed under the sanctions
program. EU persons and entities are also prohibited from making funds
available to these sanctioned persons or entities.
3.3. Sanctions against Turkey
These sanctions (Council Regulation 2019/189026) are the consequence of
Turkey’s drilling activities in relation to hydrocarbon exploration, production
and extraction, which have not been authorised by the Republic of Cyprus.
The new sanctions program establishes a framework that makes it possible
to sanction persons or entities responsible for or involved in these
unauthorised drilling activities.
Potential sanctions include a travel ban and the freezing of funds and
economic resources of the persons or entities listed under the sanctions
program. EU persons and entities are also prohibited from making funds
available to these sanctioned persons or entities.
24 Council Regulation (EU) 2019/796 of 17 May 2019 concerning restrictive measures against cyber-attacks
threatening the Union or its Member States, available at https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=uriserv:OJ.LI.2019.129.01.0001.01.ENG&toc=OJ:L:2019:129I:TOC.
25 Council Regulation (EU) 2019/1716 of 14 October 2019 concerning restrictive measures in view of the
situation in Nicaragua, available at https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=uriserv:OJ.L_.2019.262.01.0001.01.ENG.
26 Council Regulation (EU) 2019/1890 of 11 November 2019 concerning restrictive measures in view of
Turkey’s unauthorised drilling activities in the Eastern Mediterranean, available at https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.L_.2019.291.01.0003.01.ENG.
9
No persons or entities have yet been sanctioned under these new sanctions
programs. Hence, it remains to be seen whether sanctions will be effectively
imposed.
Key contacts
Doug Davison
Partner, Washington, D.C.
Tel: +1 2026549244
Mob:+1 3015293623 [email protected]
Sean Solomon
Senior U.S. Associate, Washington, D.C.
Tel: +1 2026549260
Mob: +1 2023405616 [email protected]
Sterling Darling
Senior U.S. Associate, Washington, D.C.
Tel: +1 2026549219 [email protected]
Françoise Lefèvre
Partner, Brussels
Tel: +32 25019415
Mob: +32 475521144 [email protected]
Michael Lamson
Counsel, Hong Kong
Tel: +852 29015535
Mob: +852 51916265 [email protected]
Stefaan Loosveld
Partner, Brussels
Tel: +32 25019521
Mob: +32 478980944 [email protected]
Xavier Taton
Partner, Brussels
Tel: +32 25019472
Mob: +32 477773338 [email protected]
Liesbeth Truyens
Managing Associate, Brussels
Tel: +32 25019471
Mob: +32 497265888 [email protected]
linklaters.com
This publication is intended merely to highlight issues and not to be comprehensive, nor to provide legal advice. Should you have any questions on issues reported here or on other areas of
law, please contact one of your regular contacts, or contact the editors.
© Linklaters LLP. All Rights reserved 2020
Linklaters LLP is a limited liability partnership registered in England and Wales with registered number OC326345. It is a law firm authorised and regulated by the Solicitors Regulation
Authority. The term partner in relation to Linklaters LLP is used to refer to a member of the Linklaters LLP or an independent consultant or, outside of Belgium, an employee of Linklaters LLP or
any of its affiliated firms or entities with equivalent standing and qualifications. A list of the names of the members of Linklaters LLP and of the non-members who are designated as partners
and their professional qualifications is open to inspection at its registered office, One Silk Street, London EC2Y 8HQ, England, or on www.linklaters.com. This document contains confidential
and proprietary information. It is provided on condition that its contents are kept confidential and are not disclosed to any third party without the prior written consent of Linklaters. Please refer to
www.linklaters.com/regulation for important information on our regulatory position.
We process your data in line with our Global Privacy Notice. You can view this at www.linklaters.com/en/legal-notices/privacy-notice.
To opt-out of receiving any marketing emails from us, or to manage your email preferences and the personal details we hold for you, please contact: [email protected].
For general enquiries please contact
Linklaters LLP
601 Thirteenth Street NW
Suite 400 South
Washington, D.C.
20005
Tel: +1 2026549200
Fax: +1 2126549210
Linklaters LLP
1345 Avenue of the Americas
New York, NY
10105
Tel: +1 2129039000
Fax: +1 2129039100
Linklaters LLP
Rue Brederode 13
B - 1000 Brussels
Tel: +32 25019411
Fax: +32 25019494