Aaron R. Hutman

Aaron R. Hutman

Pillsbury Winthrop Shaw Pittman LLP

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EU Proposes Significant Changes to Anti-Money Laundering Laws

Policy makers in Europe continue to explore responses to the Panama Papers revelations and recent terrorist attacks. On 28 February, European law makers approved important amendments to the EU’s Anti-Money Laundering (AML)...more

3/10/2017 - Anti-Money Laundering Customer Due Diligence (CDD) EU Terrorist Financing Regulations Virtual Currency

Great Expectations - DOJ holds anti-corruption compliance programs to a high standard in evaluating their credibility

On February 8, 2017, the U.S. Department of Justice (DOJ) released a list of important topics and sample questions that the Criminal Division’s Fraud Section has frequently found relevant in evaluating the adequacy of a...more

3/10/2017 - Compliance Corporate Misconduct DOJ Ethics FCPA Federal Pilot Programs Fraud Internal Reporting Policies and Procedures Risk Assessment Tone At The Top Yates Memorandum

General License for Commercial Authorizations from Sanctioned Russian Security Agency

OFAC has issued a new General License to address problems raised by the sanctioning of the Federal Security Services (FSB). This adjustment serves to authorize permits by the FSB needed for certain commercial transactions...more

2/6/2017 - Executive Orders FSB General Licenses OFAC Russia Sanctions

New General License Authorizes Transactions with Sudan

Effective January 17, 2017, a new general license authorizes a broad range of activities previously prohibited under the Sudanese Sanctions Regulations (SSR), including most transactions with individuals and entities in Sudan...more

1/18/2017 - BIS ECCNs General Licenses OFAC Sanctions SDN List Sudan TSRA

New OFAC Guidance Offers Clarity on Operations Involving Iran

On December 15, 2016, the Office of Foreign Assets Control (OFAC) provided updated guidance on what companies can expect in the event of the “snapback” of sanctions under the Joint Comprehensive Plan of Action (JCPOA). ...more

12/22/2016 - Iran Iran Sanctions Joint Comprehensive Plan of Action (JCPOA) OFAC

On the Eve of a New Administration, Sanctions on North Korea Tighten

On November 30, 2016, the United Nations Security Council (UNSC) passed a unanimous resolution strengthening sanctions against North Korea. The Resolution comes in response to the conduct of the latest round of nuclear tests...more

12/15/2016 - Asset Freeze Executive Orders North Korea OFAC Sanctions SDN List UN Security Council United Nations

International Trade in the Trump Era — Issues to Watch

Donald Trump’s victory in the 2016 Presidential election put the Republican Party in charge of the White House and Congress for the first time in a decade. President-elect Trump ran as an anti-establishment candidate who...more

11/15/2016 - Export Controls NAFTA Presidential Elections Sanctions Trans-Pacific Partnership Trump Administration TTIP

U.S. Government Continues to Create New Opportunities for Trade with Cuba

Both the U.S. Treasury’s Office of Foreign Assets Control (OFAC) and the Department of Commerce’s Bureau of Industry and Security (BIS) have announced new amendments to the Cuban Assets Control Regulations (CACR) and Export...more

10/17/2016 - BIS Corporate Counsel Cuba Cuban Assets Control Regulations (CACR) EAR Exports OFAC Sanctions

U.S. Announces End of Myanmar Sanctions – What Will Go and What Remains?

On September 15, 2016, President Obama announced that U.S. economic sanctions on Myanmar (also known as Burma) would end, but the announcement left many questions as to what would change and what sanctions might remain. On...more

10/11/2016 - Anti-Money Laundering Economic Sanctions Financial Institutions FinCEN Myanmar Patriot Act Popular SDN List

Redefining U.S. Export Controls: Takeaways from Key Changes Effective September 1st

On September 1, 2016 new rules previously published by the U.S. Department of Commerce, Bureau of Industry and Security (BIS) and the U.S. Department of State, Directorate of Defense Trade Controls (DDTC) will become...more

9/6/2016 - BIS DDTC EAR Export Controls ITAR US Department of State

Redefining U.S. Export Controls: Takeaways from Key Changes Effective September 1st

On September 1, 2016 new rules previously published by the U.S. Department of Commerce, Bureau of Industry and Security (BIS)1 and the U.S. Department of State, Directorate of Defense Trade Controls (DDTC)2 will become...more

9/2/2016 - BIS Cloud Computing Corporate Counsel Data Security DDTC Digital Data Encryption Export Administration Regulations Export Controls Exports ITAR Modification Passwords

US Terminates Arms Embargo Policy for Vietnam

On May 23, 2016, during President Obama’s visit to Ho Chi Minh City, the United States announced the termination its long-standing arms embargo policy for Vietnam. Exports of defense articles and defense services to Vietnam...more

5/25/2016 - Arms Embargo DDTC ITAR Trans-Pacific Partnership

A New Age of Transparency: U.S. Announces

On May 11, 2016, the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Department of Treasury, published its final rule addressing Customer Due Diligence Requirements for Financial Institutions (CDD Rule)....more

5/19/2016 - Banks Customer Due Diligence (CDD) Due Diligence Financial Institutions FinCEN Risk Assessment Transparency

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 (SARs) 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

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