Cheryl Palmeri

Cheryl Palmeri

Bass, Berry & Sims PLC

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OFAC Sanctions: No Entity Too Small or Too Far for Enforcement

- Canadian bank pays penalties for U.S. dollar transactions involving Cuba and Iran - Bank receives Finding of Violation – but no penalty – for violations by European subsidiaries - Disclosure and cooperation...more

1/30/2017 - Banks Canada Cuba Cuban Assets Control Regulations (CACR) Economic Sanctions Enforcement Actions Exports Financial Transactions Foreign Subsidiaries Imports Iran Sanctions OFAC Sanction Violations Settlement

Freaky Friday – U.S. Unexpectedly Eases Sanctions on Sudan

- Virtually all U.S. sanctions on Sudan lifted effective January 17, 2017 - Sanctions could be permanently lifted in six months - There continue to be practical challenges to doing business in Sudan...more

1/19/2017 - Barack Obama EAR Economic Sanctions Executive Orders Exports General Licenses New Guidance OFAC Revocation State Sponsors of Terrorism Sudan

Hey! Did You Hear? The United States Imposed Sanctions Against Russia.

For those of us who live and breathe U.S. economic sanctions, we are used to most people largely ignoring what goes on in our world. The United States’ recent imposition of new sanctions against Russia, however, was not one...more

1/4/2017 - Barack Obama CIA Congressional Investigations & Hearings Cyber Attacks Cyber Crimes Economic Sanctions Executive Orders FBI OFAC Presidential Elections Public Officials Russia SDN List Trump Administration Vladimir Putin

Happy New Year: OFAC Expands Exports of Medical Devices to Iran

Effective December 23, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) amended the Iranian Transactions and Sanctions Regulations (ITSR) to expand the scope of medical devices that can be exported to...more

12/28/2016 - Country of Origin Exports FFDCA General Licenses Iran Iran Sanctions ITSR Medical Devices OFAC

Happy (End of the) Holiday: OFAC Signals Potential Iran Sanctions Snapback

In what may be a harbinger of things to come, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) has issued new guidance regarding what may occur if the United States re-implements economic sanctions...more

12/16/2016 - Economic Sanctions Iran Sanctions Joint Comprehensive Plan of Action (JCPOA) OFAC Trump Administration

Still Serious About Sanctions: OFAC Settles Violations Involving Cuba and Iran

Lest U.S. companies think that Cuba and Iran are entirely open for business, a U.S. government settlement announced earlier this month with National Oilwell Varco, Inc. (NOV), a U.S. oilfield services company, will serve as a...more

11/29/2016 - Civil Monetary Penalty Cuba Economic Sanctions Enforcement Actions Exports Iran Iran Sanctions Non-Prosecution Agreements OFAC Sanction Violations Settlement UK

Post-Election Sanctions Hangover

With the results in from the U.S. presidential election, companies should begin to consider the potential impact of a Trump presidency on their international business. U.S. economic sanctions were among the hot-button issues...more

11/22/2016 - Barack Obama Cuba Economic Sanctions Executive Orders Federal Contractors General Licenses Iran Joint Comprehensive Plan of Action (JCPOA) OFAC Repeal Russia Trump Administration

Iran on Your Mind? The FAR Should Be, Too.

Over the past year, the big news for companies doing or considering business in Iran has been the scaling back of U.S. and EU economic sanctions. Many global businesses are now permitted to operate in this once prohibited...more

11/2/2016 - Certification Requirements Economic Sanctions False Claims Act (FCA) Federal Acquisition Regulations (FAR) General Licenses Iran Iran Sanctions Joint Comprehensive Plan of Action (JCPOA) OFAC Popular System For Award Management (SAM)

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