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The Long Arm of U.S. Sanctions: Penalty Imposed Against Canadian Subsidiary of U.S. Subsidiary of Japanese Company

On June 8, the Office of Foreign Assets Control (OFAC) announced a monetary penalty against American Honda Finance Corporation (American Honda) for alleged violations of the Cuban Assets Control Regulations (CACR), the...more

Proposed Legislation Would Combat Terrorist Financing, Money Laundering

- Proposed legislation targets current gaps in U.S. financial crime law and enforcement - Bi-partisan Senate legislation would likely expand compliance obligations for banks and others in financial services industry -...more

Buy American Executive Order Means Renewed Obligations for Government Contractors

On April 18, President Trump signed the “Presidential Executive Order on Buy American and Hire American” (the Order), which declares the Executive branch’s policy to buy American goods and rigorously enforce and administer...more

The Long Road: Boeing Continues the March into Iran

- Boeing announces deal to sell aircraft to Iran Aseman - The deal was apparently authorized by the U.S. Treasury Department, but Congressional foes fight to block it - If the deal goes through, further loosening of...more

Lessons from the Historic ZTE Enforcement Action

On March 7, 2017, Chinese telecommunications company, Zhongxing Telecommunications Equipment Corp. (ZTE), signed on to three separate settlement agreements with the United States, agreeing to pay $892 million for violations...more

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

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

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

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

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

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

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

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

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