Doreen Edelman

Doreen Edelman

Baker Donelson

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Secondary Sanctions Can Prove Tricky for Both U.S. and Non-U.S. Companies - Export Compliance Matters

What are secondary sanctions? Secondary sanctions apply to non-U.S. persons for wholly non-U.S. conduct that occurs entirely outside U.S. jurisdiction. Compare this to primary sanctions, which prohibit U.S. persons from...more

7/29/2016 - OFAC Parent Corporation Sanctions SDN List Subsidiaries

Commerce Guidance Supports Benefits of Voluntary Disclosures and Improved Compliance Programs

The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) has issued a voluntary disclosure guidance for export violations. The guidance takes effect July 22 and its intent is to make Commerce’s enforcement more...more

7/25/2016 - BIS Exporters OFAC Self-Disclosure Requirements U.S. Commerce Department

New Opportunities in Cuba for Universities

The Administration's recent efforts to normalize trade relations with Cuba has resulted in new opportunities for universities. Although the embargo is still in place, the Administration has carved out multiple exceptions....more

6/23/2016 - Cuba Educational Institutions Export Administration Regulations Humanitarian Assistance OFAC Universities

Exporting to Sri Lanka? — If Not, It May Be Time to Consider the Market

Sri Lanka may not be the first market that comes to mind when thinking of opportunities to export goods and services or invest, but there is reason to at least keep the country in mind. While the Administration has been busy...more

6/20/2016 - Exporters Investors Trans-Pacific Partnership Transatlantic Trade and Investment Partnership

2016 Top Export Markets for U.S. Goods

Last week the Commerce Department’s International Trade Administration (ITA) released the second installment of its Top Markets Reports. The reports–nineteen different industries are highlighted in total–do an excellent job...more

6/15/2016 - Exporters Exports Federal Aviation Administration (FAA) Manufacturers Medical Devices WTO

Watch Out – CBP Is Coming After Importers for Duties and Compliance Will be Key

U.S. importers should reevaluate their compliance program as U.S. Customs and Border Protection (CBP)’s steps up its efforts to enforce payment of antidumping and countervailing duties. The efforts come at the heel of this...more

6/13/2016 - Anti-Dumping Duty Countervailing Duties Customs and Border Protection Importers Trade Facilitation and Trade Enforcement Act

The Current Playing Field for Cuba – A Summary of the Existing Requirements

The Department of Treasury and Department of Commerce have made several changes to the Cuban Assets Control Regulations (CACR) and the Export Administration Regulations (EAR) since the Administration announced its new...more

6/7/2016 - Cuba Cuban Assets Control Regulations (CACR) EAR Exports Imports

OFAC Further Amends Cuban Assets Control Regulations – President Obama Authorizes More Travel and U.S. Presence in Cuba

On March 16, 2016, in what could be the final set of amendments to the Cuban Assets Control Regulations (CACR) under the Obama Administration, the Office of Foreign Assets Control (OFAC) published a final rule that further...more

5/19/2016 - Cuban Assets Control Regulations (CACR) Final Rules General Licenses OFAC Trade Relations

New Commerce Department Procedure Available for U.S. Cuba License Holders – It’s a Bit Hard to Find, But if You Need It, You Need...

We all know that export regulations cannot keep up with reality. Reforms are happening very quickly, especially regarding Cuba. So, here’s a new procedure we just discovered. Perhaps it can help you if you are ever similarity...more

5/9/2016 - BIS Cuba Cuban Assets Control Regulations (CACR) Export Controls Exports OFAC U.S. Commerce Department

Please Read the Fine Print About Doing Business in Cuba

I am here to encourage newly authorized trade to and from Cuba. However, my job is also to ensure that exporters have all of the information they need to make informed business decisions and remain compliant with U.S. trade...more

4/1/2016 - BIS Business Development Cuba Cuban Assets Control Regulations (CACR) Export Administration Regulations General Licenses OFAC Sanctions SDN List

Commerce at its Best – A True Export Promotion Tool for U.S. Exporters

Trade Agreements are political hot potatoes, which as a trade attorney I always find interesting. The presidential candidates have been debating the pros and cons of trade agreements for years from a 60,000 foot level. Is the...more

3/29/2016 - Export Controls Exports Tariffs Trade Agreements Trade Relations Trans-Pacific Partnership

OFAC Further Amends Cuban Assets Control Regulations – President Obama Authorizes More Travel and U.S. Establishments in Cuba in...

On March 16, 2016, in what could be the final set of amendments  to the Cuban Assets Control Regulations (CACR) under the Obama Administration, the Office of Foreign Assets Control (OFAC) published a Final Rule that further...more

3/18/2016 - Barack Obama Cuba Cuban Assets Control Regulations (CACR) OFAC Sanctions Travel Permits

U.S. Tax Considerations for Corporate Dealings in Cuba

On March 1, 2016, the Internal Revenue Service (IRS) issued Revenue Ruling 2016-8, which removed Cuba from a blacklist of foreign countries that are denied certain favorable tax rules under the Internal Revenue Code (IRC)....more

3/14/2016 - Corporate Taxes Cuba Foreign Relations Foreign Tax Credits Internal Revenue Code (IRC) IRS Sanctions

Tips To Avoid Inadvertent Violations of OFAC’s Sanctions Against Russia

A year ago I posted an overview of OFAC’s Ukraine and Russia-related sanctions program. Although the Executive Orders and program structure described in that post have not been changed or expanded, it is important to remember...more

2/19/2016 - Crimea Economic Sanctions OFAC Russia SDN List

Cyber Activities Added to the OFAC Target List – How do you ensure you are compliant?

In December of 2015 the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued regulations implementing the President’s April 1, 2015 Executive Order (“EO”), “Blocking the Property of Certain Persons...more

1/27/2016 - Cyber Crimes Cybersecurity Executive Orders OFAC Popular SDN List

Enforcement Update – DOJ Raises Focus on Prosecuting Individuals

There has been a change in the US Department of Justice regarding corporate disclosures. The recently updated United States Attorney’s Manual has revised its provisions called the “Principles of Federal Prosecution of...more

12/17/2015 - Corporate Culture Criminal Prosecution DOJ Filip Factors Voluntary Disclosure

Weak Compliance Programs Won’t Protect You from Criminal Misconduct

The Department of Justice’s (DOJ’s) Criminal Division has now hired “Compliance Counsel” but the Department has no plans to move towards making a formal compliance defense available to those charged with regulatory...more

12/9/2015 - Compliance Corporate Crimes Corporate Misconduct DOJ Policies and Procedures Third-Party

You Want to Export to Cuba? Get Ready, But You Probably Can’t Quite Yet.

New rules came out on September 21, 2015 from both the Commerce and Treasury Departments. Although for the most part these changes only slightly broaden or clarify pre-existing exceptions to the embargo against Cuba, they...more

9/25/2015 - Aircraft Equipment Aviation Industry Bank Accounts Banking Sector Banks BIS Cuba Embargo Export Controls Financial Institutions Internet OFAC Popular Private Sector U.S. Commerce Department U.S. Treasury

Think Big Picture – minimize corporate export compliance risks while protecting your information security

Recently I have attended several cyber security conferences. What I have learned about protecting information has changed how I view export controls. Senior management and board members should think about the big picture as...more

9/2/2015 - Board of Directors Compliance Cyber Attacks Cyber Crimes Cybersecurity Data Breach Data Security Export Controls Hackers Information Technology Non-Disclosure Agreement Risk Management Target

Attention Exporters: C-TPAT Web Portal Updated Adding Exporter Application

The Customs-Trade Partnership Against Terrorism (C-TPAT) certification program is a voluntary government program through which importers and exporters can agree to implement and maintain a set of predetermined supply chain...more

8/28/2015 - Applications C-TPAT Customs and Border Protection Exporters Exports Importers Imports Required Documentation Supply Chain U.S. Customs

Is Iran Open for Business for U.S. Exporters?

On August 7, 2015, the U.S. Government issued a revised Guidance regarding Iran and also issued a Third Amended Statement of Licensing Policy on Activities Related to the Safety of Iran’s Civil Aviation Industry. The bottom...more

8/21/2015 - Aircraft Automotive Industry Aviation Industry China Crude Oil Energy Sector Exports Foreign Entities Humanitarian Assistance India Iran Iran Sanctions Japan Medical Equipment Medical Supplies OFAC SDN List South Korea Taiwan Turkey U.S. Treasury United Nations

Limited Access to Cuba but it is a Start for U.S. Businesses

As you know there are ongoing changes to the Cuba export regulations. President Obama announced the reopening of the U.S. embassy in Havana and a Cuban embassy in Washington. The Commerce Department will remove Cuba from list...more

7/31/2015 - Airlines Aviation Industry Cuba Embargo Exports Obama Administration OFAC State Sponsors of Terrorism U.S. Commerce Department

Iran – Don’t Forget the General License!

Iran entered into a historic nuclear agreement with the U.S. and other world powers on July 14th 2015. The agreement will allow the licensing of the export, re-export, sale, lease or transfer to Iran of commercial passenger...more

7/27/2015 - Aircraft Airlines Compliance Due Diligence Exports Iran Iran Sanctions Nuclear Power OFAC Power Plants Sanctions

Attention Exporters: Passage of ‘Fast-Track’ Bill Sets the Stage for America’s Next Big Trade Deal

The Idea Behind TPA - On September 24 a rare alliance between Republicans and the Obama Administration led to passage of the ‘fast-track’ bill granting the President a 6-year renewal of Trade Promotion Authority (TPA). As a...more

6/29/2015 - Export Controls Exporters Exports Trade Policy Trade Promotion Authority Trans-Pacific Partnership

Compliance Officers Can Face Individual Liability for Corporate Importation Violations

Corporate officers and shareholders take note: personal liability for unpaid duties may result from material misrepresentations on import documentation even when the importer of record is a corporate entity. The corporate...more

6/15/2015 - Best Management Practices C-Suite Executives Chief Compliance Officers Corporate Veil Diminution in Value False Reporting Imports Material Misstatements Personal Liability

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