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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

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

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

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

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

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

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

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

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

Sanctions on Russia Expanded Despite Tenuous Truce

On Friday , September 12th, while a tenuous truce between Ukraine and rebel forces showed signs of cracking and government officials continued to trade verbal jabs, the United States amped up pressure on Russia by expanding...more

9/18/2014  /  Russia , Sanctions , Ukraine

Big Talk After a Cautious Expansion of Ukraine-Related Sanctions by the U.S. – But Still No Big Changes for U.S. Exporters

Although Obama Administration officials undoubtedly recognize the need to punish Russia and Russian-backed rebels for their alleged role in the MH17 tragedy, they also will continue to weigh the effects of further sanctions...more

7/25/2014  /  Foreign Policy , Russia , Sanctions , Ukraine

Prohibited Country Sanctions and Embargoes: Make Sure You Know the Difference When Drafting Contract Language and Evaluating...

Casually, the words ‘embargo’ and ‘sanction’ are often used interchangeably. But when it comes to drafting a contract or assessing the viability of an export opportunity, failing to use the correct word can have serious...more

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

Exporters Pushing Back On Threats of Further Sanctions on Russia

Until recently, American trade associations including the U.S. Chamber of Commerce and the National Association of Manufacturers have made their opposition to the imposition of further sanctions on Russia known to the...more

No New Export Licenses For Items, Services, or Information Destined For Russia — Be Careful with Russian Nationals in the U.S.

The Commerce Department’s Bureau of Industry and Security (BIS) and the State Department’s Directorate of Defense Trade Controls (DDTC), the two offices in charge of issuing export licenses for controlled dual-use and defense...more

Issuance of a new Ukraine-related Executive Order

As you know, sanctions have profound ripple effects and with the U.S. response to the continuing crisis in Crimea, it is imperative you ensure that these newly-ordered sanctions dont trickle down to doing business with your...more

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

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