Doreen Edelman

Doreen Edelman

Baker Donelson

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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

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

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

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

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

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 Cuba Cuban Assets Control Regulations (CACR) 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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