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OFAC Fines American Honda for Foreign Subsidiary’s Business with Cuba

American Honda Finance Corporation (American Honda) has settled with the Office of Foreign Assets Control (OFAC) over potential civil liability for 13 violations of the Cuban Assets Control Regulations (CACR), which that...more

OFAC Imposing Penalties on Non-U.S. Companies

A recent OFAC enforcement case illustrates that even non-U.S. companies that do business with sanctioned jurisdictions under the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) face significant risks...more

8/7/2017  /  Economic Sanctions , Exports , OFAC

Treasury Department Issues FAQ on Impact of Cuba Policy Shift

On June 16, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) issued a press release answering 12 "Frequently Asked Questions" ahead of President Trump's announcement of a revised U.S. policy...more

OFAC Enforcement Trends in the Health Care, Agriculture and Tech Industries

The United States Department of the Treasury's Office of Foreign Assets Control (OFAC), the U.S. governmental agency tasked with administering and enforcing economic sanctions against hostile targets in furtherance of U.S....more

OFAC’s Broad Latitude To Impose Iran Sanctions Affirmed by D.C. Circuit

A D.C. Circuit Court of Appeal’s panel recently issued a key opinion affirming the U.S. Treasury Department’s broad ability to enforce sanctions regulations through its Office of Foreign Assets Control (“OFAC”). While the...more

6/19/2017  /  Exports , Iran , Iran Sanctions , ITSR , OFAC

Update on Regulatory Compliance in the Global Health Care Industry

A comprehensive understanding of the constantly evolving layers that make up federal anti-corruption statutes, sanctions regulations and export control restrictions is imperative for both the pharmaceutical and health care...more

Three Important Lessons to Be Learned from the $1.2 Billion ZTE Settlements

On March 7, we learned that Zhongxing Telecommunications Equipment Corporation (ZTE) concluded 3 settlement agreements that could result in penalties as high as $1.2 billion for its violations of U.S. sanctions and export...more

Another Reason To Always Run Compliance Screenings Even If You Are A Non-U.S. Party – OFAC Is Targeting Foreign Companies

If you are a foreign company that wants access to the U.S. financial markets, make sure you understand the U.S. Iran Transactions and Sanctions Regulations (ITSR). Administered by the U.S. Department of Treasury’s Office of...more

Iran and Russia Sanctions Programs Under a Trump Administration–What to Expect

In the final weeks of December, President Obama amended sanctions to both the Iran and Russia programs. These changes further relaxed sanctions on Iran while they tightened sanctions on Russia. Yet, just three days from the...more

New Changes to Sanctions on Cuba Provide New Array of Business Opportunities in Cuba–What You Should Know

Sanctions against Cuba continue to lift. Effective this week, the Department of Treasury’s Office of Foreign Assets Control (OFAC) and the Department of Commerce’s Bureau of Industry and Security (BIS) have relaxed controls...more

10/20/2016  /  BIS , Cuba , Exports , OFAC , Sanctions

New License Authorizing U.S. Aircraft to Make Temporary Sojourns to Iran Marks Further Lifting of Secondary Sanctions

Further weakening secondary sanctions, the Department of Treasury’s Office of Foreign Assets Control has issued a new license to allow non-U.S. persons to fly some U.S. aircraft to Iran for temporary sojourn. While General...more

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

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

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

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

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

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

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

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

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

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

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

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

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

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