Aaron R. Hutman

Aaron R. Hutman

Pillsbury Winthrop Shaw Pittman LLP

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OFAC Provides Helpful New Guidance for Cuba

The Office of Foreign Assets Control (OFAC) updated its FAQs for Cuba on April 21, 2016 with substantive guidance that addresses U-turn transactions, export policy, insurance, educational and humanitarian activities and...more

4/26/2016 - Corporate Counsel Cuba Cuban Assets Control Regulations (CACR) Exports Insurance Contracts Leases OFAC State-Owned Enterprises U-Turn Transactions

Additional Steps to Ease U.S. Sanctions and Export Controls for Cuba prior to Obama Visit

In advance of President Obama’s highly publicized trip to Cuba, the Administration took additional steps to ease restrictions on trade and travel with Cuba. These changes to the Cuban Assets Control Regulations (CACR) and...more

4/12/2016 - Banking Sector Barack Obama Cuba Cuban Assets Control Regulations (CACR) EAR Economic Sanctions Export Controls Exports OFAC Physical Presence Test Shipping Travel

UN and U.S. Sanctions Target North Korea: Impacts for Asia and Beyond

The United Nations and United States recently took significant new steps to expand sanctions on North Korea, with implications for international banking; shipping and port activities; air transport; energy and mining sectors;...more

4/6/2016 - Asia China Economic Sanctions International Finance Minerals North Korea Oil & Gas Shipping South Korea UN Security Council

Additional Steps to Ease U.S. Sanctions and Export Controls for Cuba prior to Obama Visit

In advance of President Obama’s highly publicized trip to Cuba, the Administration took additional steps to ease restrictions on trade and travel with Cuba. These changes to the Cuban Assets Control Regulations (CACR) and...more

4/5/2016 - Barack Obama BIS Cuba Cuban Assets Control Regulations (CACR) EAR Exports Financial Sector Imports OFAC Travel

UN and U.S. Sanctions Target North Korea: Impacts for Asia and Beyond

The United Nations and United States recently took significant new steps to expand sanctions on North Korea, with implications for international banking; shipping and port activities; air transport; energy and mining sectors;...more

4/4/2016 - Censorship Economic Sanctions Embargo Executive Orders Human Rights International Finance North Korea Oil & Gas Shipping U.S. Treasury UN Security Council

What about Canada and Australia? Iran Sanctions changes beyond the U.S. and EU

There has been much discussion of U.S. and EU sanctions changes following Implementation Day under the Joint Comprehensive Plan of Action (“JCPOA”), but a number of countries had imposed sanctions for Iran and it is worth...more

2/29/2016 - Australia Canada Export Controls Exports Financial Sector Imports Iran Sanctions Joint Comprehensive Plan of Action (JCPOA) Nuclear Power SDN List United Nations

FinCEN Proposes to Regulate Investment Advisers under the Bank Secrecy Act

The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking on August 25, 2015 which, among other things, would add SEC-registered investment advisers to the “financial...more

9/2/2015 - Anti-Money Laundering Bank Secrecy Act BSA/AML Currency Transaction Reports (CTR) Financial Institutions FinCEN Investment Adviser Reporting Requirements SEC Suspicious Activity Reports U.S. Treasury

The UK Appoints New Anti-Corruption Unit: A Look at the Global Ramifications

Given London’s role in international business and finance, the UK Bribery Act 2010 promised to form a potential strong counterpart to the U.S. Foreign Corrupt Practices Act (FCPA). Now, the UK government is taking steps which...more

8/27/2015 - Anti-Corruption Enforcement Actions FCPA International Corruption Unit (ICU) SFO UK UK Bribery Act

Framework for Nuclear Agreement with Iran Announced—But Still a Long Way to Go

On April 2, 2015 representatives of the United States, Britain, France, Germany, China and Russia (collectively, the “P5+1” countries) announced that they had agreed with the Islamic Republic of Iran on the Parameters for a...more

4/27/2015 - Iran Nuclear Power P5+1 Nations Sanctions

New Executive Order Allows for Sanctions Related to Cybersecurity

On April 1, 2015, President Obama issued a groundbreaking Executive Order (E.O.) enabling the United States to sanction persons that have (1) participated in malicious cyber-enabled activities constituting a “significant...more

4/24/2015 - Barack Obama Critical Infrastructure Sectors Cyber Threats Cybersecurity Executive Orders National Security Sanctions

A New U.S. Course for Cuba Relations: What Does It Mean for Business?

President Obama made an unexpected announcement this week signaling a “new course” for Cuba after more than fifty years of comprehensive U.S. sanctions. Reestablishing diplomatic relations is a major change. In terms of...more

12/19/2014 - Barack Obama Cuba Export Controls Foreign Policy Sanctions

U.S. and EU Extend Temporary Iran Sanctions Relief a Second Time

The temporary and limited changes to U.S. and European Union (“EU”) sanctions policy for Iran, as agreed under the interim nuclear deal reached by Iran and the P5 + 1 countries, have been extended until June 30, 2015. Most...more

12/4/2014 - Automotive Industry EU Export Controls Iran Sanctions Oil & Gas Time Extensions

Doing Business in the United States

In This Book: - Choice Of A Business Entity - Introduction To Federal Securities Laws - From Let’s Go Shopping To Closing: M&A Process In The United States - Employment Considerations -...more

10/16/2014 - Business Formation Choice of Entity Commercial Real Estate Market Corporate Taxes Dispute Resolution Energy Policy Environmental Policies Foreign Investment Immigration Procedures International Trade Agreements Securities Act of 1933 Securities Exchange Act

U.S. Steps Up Sanctions and Export Controls Against Russia’s Defense Industry

The United States recently expanded sanctions and export controls against the Russian defense sector. These designations and export control steps have implications for defense contractors, parts suppliers and brokers....more

9/30/2014 - Banking Sector BIS Defense Sector Energy Sector Export Controls OFAC Russia Sanctions SDN List U.S. Commerce Department

OFAC Makes Important Update to Ownership/Control Guidance

On August 13, 2014, the Office of Foreign Assets Control (OFAC) issued new guidance on ownership/control for determining blocked parties. This represented the first significant update on this topic since February 14, 2008,...more

9/2/2014 - Compliance Due Diligence Foreign Policy OFAC Sanctions

Further European Union Sanctions Target Russia, Whilst Russia Retaliates

The United States, European Union and Canada each took steps recently to expand sanctions against Russia, including the targeting of major defense companies and the addition of export controls. These designations and export...more

8/11/2014 - EU Russia Sanctions

Western Sanctions Expand as Tension in Ukraine Continues

The United States, Canada and the European Union have designated a number of additional officials and companies as the unrest continues in eastern Ukraine. The United States also imposed sanctions on the head of Russian...more

5/15/2014 - Banking Sector BIS Canada Energy Market EU OFAC Rosneft Sanctions Ukraine

European Subsidiary Incurs Liability Under U.S. Cuba Sanctions for Travel Services

On April 18, 2014, the Office of Foreign Assets Control (“OFAC”) announced a settlement of nearly $6 million with CWT B.V. (“CWT”) for violations of the Cuban Assets Control Regulations (“CACR”), 31 C.F.R. Part 515. CWT is a...more

4/24/2014 - Cuba Foreign Subsidiaries OFAC Sanctions Travel

U.S. and UK Take Modest Steps to Restrict Exports to Russia

The Obama Administration has threatened to impose additional sanctions on Russia in response to the Ukraine crisis but so far has only blocked the assets of 32 individuals and one bank. Additionally, with little fanfare, the...more

4/2/2014 - Exports Foreign Policy Russia Sanctions UK

Ukraine/Russia Sanctions Escalate

Sanctions escalated at a rapid pace last week as western powers responded to the crisis in Ukraine and Russian’s annexation of Crimea. The United States, European Union (EU), Canada and Australia have implemented sanctions....more

3/26/2014 - Foreign Policy Russia Sanctions Ukraine

New Ukraine Sanctions Announced – U.S., EU and Canada Take Action

In response to political developments in the Ukraine and Russian military action in Crimea, the United States and European Union (EU) announced new sanctions on March 6, 2014. Canada issued its sanctions on March 5, 2014. The...more

3/11/2014 - Canada EU Foreign Policy Ukraine

U.S. Ex-Im Bank Opens for Business in Burma/Myanmar

The U.S. Government has taken another important step in helping to reintegrate Myanmar (referred to as Burma for official purposes) into the global economy. On February 6, 2014, the Export-Import Bank of the United States...more

2/21/2014 - Banks Exports Foreign Policy Trade Policy

United States Implements Temporary Changes to Iran Sanctions under Interim Agreement

On January 20, 2014, the U.S. Treasury and State Departments took steps to implement temporary and limited changes to U.S. sanctions policy for Iran as agreed under the interim nuclear deal reached by Iran and the P5 + 1...more

1/23/2014 - EU Foreign Policy Iran Iran Sanctions Middle East OFAC U.S. Treasury US Department of State

Interim Deal on Iran Sanctions Policy Involves Limited Changes

Despite some confusing media reports, the interim nuclear deal reached by Iran and the P5 + 1 on November 24, 2013 would change very little in U.S. and multilateral sanctions policy. These limited changes are still pending...more

11/27/2013 - EU International Trade Agreements Iran Sanctions Joint Plan of Action Nuclear Power

State Department Publishes Interim Final Rule to Clarify Defense-Broker Requirements

Section 38(f) of the Arms Export Control Act requires the registration of brokers of defense articles and defense services, pursuant to regulations currently published in Part 129 of the International Traffic in Arms...more

8/29/2013 - Department of Defense (DOD) ITAR Registration US Department of State

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