Doreen Edelman

Doreen Edelman

Baker Donelson

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OFAC Adds 7 Venezuelan Officials to SDN List

On March 8 President Obama signed Executive Order 13692 Executive Order 13692, which initially adds seven former or current Venezuelan government officials to OFAC’s Specially Designated Nationals (SDN) List. Once they have...more

3/30/2015 - Executive Orders Foreign Official OFAC SDN List Venezuela

New Opportunities in Cuba for U.S. Travel and Medical Companies – Cigars but not Commerce

After President Obama's announcement that his Administration will pursue a policy aimed at improving U.S.-Cuba diplomatic relations and ultimately eliminating the economic embargo on Cuba, the U.S. Treasury and Commerce...more

1/30/2015 - Amended Legislation Banking Sector Barack Obama BIS CACR Cuba EAR Embargo Executive Orders Export Controls Exports Foreign Relations Imports OFAC Sanctions Telecommunications Trade Relations Travel Permits U.S. Commerce Department U.S. Treasury

Update: U.S. Ramps Up Ukraine-Related Sanctions Yet Again

On December 19th, President Obama signed Executive Order (EO) 13685 specifically targeting Crimea and those responsible for the usurpation of the peninsula back in March. This latest EO was the forth in a series aimed at...more

1/22/2015 - Banking Sector Barack Obama BIS Crimea Defense Sector Energy Sector Executive Orders Export Controls Exports OFAC Russia Sanctions SDN List SSI List Ukraine

What Will the "New Chapter" in U.S.-Cuba Relations Entail?

On January 15, both the Treasury Department's Office of Foreign Assets Control (OFAC) and the Commerce Department's Bureau of Industry and Security (BIS) published final rules implementing President Obama's initial reforms....more

1/19/2015 - Banking Sector BIS Cuba Exports Financial Institutions Foreign Policy Imports OFAC Sanctions Trade Policy Travel Permits Travelers

It’s Not Rocket Science: Taking the Steps Necessary to Avoid Costly Sanctions Violations

The $963 million settlement OFAC recently reached with French banking giant BNP Paribas SA (BNP) was both the largest OFAC settlement to date and represents only a small fraction of the nearly $9 billion in total fines...more

7/7/2014 - BNP Paribas Chief Compliance Officers OFAC Sanctions Settlement

Real OFAC Policy Changes Toward Iran—OFAC will consider non Ag/Med exports

As a new round of nuclear talks involving American, European, and Iranian leaders commence this week in Vienna it appears that the first-step deal agreed upon in January has already led to significant changes in OFAC’ s...more

4/11/2014 - Aviation Industry Exports Iran Iran Sanctions Medical Devices Middle East OFAC

BVI Company In Trouble Over Plans to Ship Engines to Iran

We usually don’t post enforcement summaries. However, I wanted to insure everyone was aware that the United States government is really going after non-U.S. entities. Please see below. Note it is the Commerce Department not...more

2/17/2014 - BVI Business Companies Exports Iran OFAC U.S. Commerce Department

Understanding OFAC’s Newest General License Regarding Personal Communication Services in Iran

The Office of Foreign Assets Control (OFAC) recently released General License D regarding the exportation of certain services, software and hardware pertaining to personal communication exchange in Iran....more

6/24/2013 - Apple Export Administration Regulations Exports Iran Sanctions Licenses OFAC Software

Burma – Trade is looking up by way of General Licenses, but caveats still remain.

Recent improvements in the political environment of Burma have allowed for some easing of sanctions, with the ultimate goal of increasing U.S. trade with Burma. Most recently, on February 22, 2013, the Department of...more

3/6/2013 - Foreign Investment Licenses OFAC Sanctions SDN List

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