Edward Rubinoff

Edward Rubinoff

Akin Gump Strauss Hauer & Feld LLP

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New Round of Cuba Sanctions Changes Expand Opportunities for Health Sector

Key Points - - OFAC’s latest changes expand opportunities for U.S. persons to engage in medical research with Cuban nationals, authorize U.S. persons to obtain FDA approval of Cuba-origin pharmaceuticals, and market...more

10/20/2016 - Cuba EAR FDA Approval Imports OFAC Pharmaceutical Industry Shipping

OFAC Guidance on U.S. Dollar Transactions Involving Iran

On October 7, 2016, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) published new guidance clarifying (a) circumstances under which non-U.S. financial institutions (FFIs) may engage in U.S. dollar...more

10/11/2016 - Foreign Financial Institutions (FFI) Iran Sanctions Joint Comprehensive Plan of Action (JCPOA) New Guidance OFAC SDN List U.S. Treasury

Russia Sanctions Update: OFAC, BIS Expand Sanctions Lists

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued new Russia/Ukraine-related sanctions on Thursday, September 1, 2016. This action marks OFAC’s first major expansion of the Specially...more

9/9/2016 - BIS OFAC Russia Sanctions SDN List SSI List Ukraine

Export Control Reform Offers Revisions to Key Terms, and DDTC Increases Penalty Authority; More Work Remains (Part 1)

On June 3, 2016, the U.S. Department of State, Directorate of Defense Trade Controls (DDTC) and the Department of Commerce, Bureau of Industry and Security (BIS) issued changes to the International Traffic in Arms Regulations...more

6/13/2016 - Amended Regulation BIS DDTC EAR Export Controls ITAR Supply Chain US Department of State

Anti-Corruption Summit: Extending Corporate Liability for Economic Crimes?

In a keynote address at the London Anti-Corruption Summit, Prime Minister David Cameron raised the possibility of new U.K. legislation to make corporations liable for “failure to prevent” fraud or money-laundering offenses...more

5/17/2016 - Anti-Corruption Associated Persons Corporate Liability David Cameron UK UK Bribery Act

OFAC Adopts New Sanctions Targeting Hizballah’s Financial and Logistics Networks

If you only read one thing... - The Hizballah Financial Sanctions Regulations (HFSR) are intended to disrupt Hizballah’s global logistics and financial network by providing a new basis of secondary sanctions...more

4/26/2016 - Economic Sanctions Foreign Financial Institutions (FFI) Hizballah OFAC SDN List

OFAC Authorizes Certain Commercial Passenger Aircraft Transactions with Iran

On March 24, 2016, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued General License I authorizing U.S. persons to undertake certain transactions ordinarily incident to the negotiation of, and...more

4/1/2016 - Aircraft Aircraft Equipment Export Controls General Licenses Iran Joint Comprehensive Plan of Action (JCPOA) OFAC

Obama Administration Further Eases Sanctions in Advance of Cuba Visit

On Wednesday, March 16, 2016, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) implemented amendments to the Cuban...more

3/18/2016 - Banking Sector Cuba Cuban Assets Control Regulations (CACR) Export Controls OFAC Trade Relations

Red Notice Newsletter - February 2016

DOJ and SEC Announce Settlement with PTC, Inc. in FCPA Case Involving SEC’s First Individual Deferred Prosecution Agreement - On February 16, 2016, the U.S. Securities and Exchange Commission (SEC) and the U.S....more

3/3/2016 - Anti-Corruption Barclays Enforcement Actions Export Controls FCPA Government Investigations OFAC Red Notices Sanctions SAP America Inc.

China Continues to Dominate CFIUS Review (Update)

On February 19, 2016, the Committee on Foreign Investment in the United States (CFIUS) released its annual report to Congress. CFIUS is an interagency committee that reviews the national security risks associated with...more

2/25/2016 - CFIUS China Covered Transactions Financial Services Industry Foreign Direct Investment Manufacturers

China Continues to Dominate CFIUS Review

On February 19, 2016, the Committee on Foreign Investment in the United States (CFIUS) released its annual report to Congress. CFIUS is an interagency committee that reviews the national security risks associated with...more

2/24/2016 - Canada CFIUS China Covered Transactions Financial Services Industry Foreign Direct Investment Manufacturers

Red Notice Newsletter - January 2016

ANTICORRUPTION DEVELOPMENTS - Convicted Printing Company Ordered to Pay £2.2 Million - On January 8, 2016, the Serious Fraud Office (SFO) announced that Smith & Ouzman Ltd, a U.K. security printing company, was...more

2/3/2016 - Africa Anti-Corruption Cash Transactions Criminal Prosecution Export Controls FCPA FinCEN Iran Sanctions Joint Comprehensive Plan of Action (JCPOA) OFAC Panama Public Officials Red Notices SAP America Inc. Serious Fraud Office UK Venezuela

Obama Administration Further Relaxes Sanctions in Support of Cuba Policy

If you read one thing… - Further relaxation of sanctions on Cuba, effective on January 27, 2016, allows U.S. financial institutions to finance authorized exports and reexports to Cuba of items other than...more

1/28/2016 - BIS Cuban Assets Control Regulations (CACR) EAR Export Controls OFAC

What Implementation of the Iran Nuclear Deal Means for Non-U.S. Companies

On January 16, 2016, the International Atomic Energy Agency (IAEA) verified, and U.S. Secretary of State John Kerry confirmed, that Iran had implemented its key nuclear-related measures described in the Joint Comprehensive...more

1/22/2016 - Export Controls Foreign Financial Institutions (FFI) IAEA Implementation Day Iran Sanctions Joint Comprehensive Plan of Action (JCPOA) Visa Waiver Program

What Implementation of the Iran Nuclear Deal Means for U.S. Companies and Their Subsidiaries Abroad

If you read one thing... - There are far greater opportunities for U.S. companies with respect to Iran, particularly through foreign subsidiaries and in the commercial aviation sector, however, U.S. persons and...more

1/19/2016 - Embargo IAEA Implementation Day Iran Sanctions Joint Comprehensive Plan of Action (JCPOA) Nuclear Power

Budget Deal Includes Repeal of U.S. Crude Oil Export Ban

On December 15, 2015, U.S. congressional leaders announced a year-end budget compromise that removes the ban on the export of crude oil from the United States. In exchange for this concession, the Democratic-led opposition to...more

12/17/2015 - Appropriation Act Crude Oil Energy Sector Export Controls Oil & Gas

Red Notice Newsletter - October 2015

Welcome to the October 2015 edition of Red Notice, a publication of Akin Gump Strauss Hauer & Feld LLP. This month on the anticorruption front, a Japanese multinational conglomerate settles U.S. Securities and Exchange...more

11/3/2015 - Arms Export Control Act Bribery Criminal Conspiracy DOJ Electronics Energy Exploration Enforcement Actions Export Controls FCPA Firearms Hitachi Iran Sanctions ITAR OFAC Oil & Gas Private Utility Red Notices Russia Sanctions SEC UK Bribery Act USML

US State Department Releases Contingent Waivers of Iran Extraterritorial Sanctions

On October 18, 2015, the day on which the Joint Comprehensive Plan of Action (“JCPOA”) became effective (“Adoption Day”), the U.S. Department of State (“State Department”) issued contingent waivers of certain extraterritorial...more

10/21/2015 - Banking Sector Energy Sector Export Controls Exports IAEA Iran Iran Sanctions Joint Comprehensive Plan of Action (JCPOA) OFAC SDN List US Department of State Waivers

U.S. Government Approves Crude Oil Swaps with Mexico While Congress Considers Repealing the Underlying Export Restrictions

On August 14, 2015, the U.S. Department of Commerce’s, Bureau of Industry and Security (BIS) indicated that it would approve a number of export license applications permitting parties in the United States to swap crude oil...more

8/18/2015 - BIS Crude Oil EAR Export Controls Exports Legislative Agendas Legislative Committees Mexico Oil & Gas U.S. Commerce Department

Sanctions Relief to Expect from the Nuclear Deal with Iran

On July 14, 2015, Iran and the P5+1 countries (China, France, Germany, Russia, the United Kingdom and the United States), with the High Representative of the European Union for Foreign Affairs and Security Policy, finalized...more

7/16/2015 - Aircraft Equipment Airlines EU Foreign Trade Regulations Imports Inspections International Atomic Energy Agency Iran Iran Sanctions Joint Comprehensive Plan of Action (JCPOA) Member State Multinationals P5+1 Nations SDN List UN Security Council United Nations

Red Notice Newsletter - June 2015

This month on the anticorruption front, an energy company announces the U.S. Department of Justice (DOJ) has declined to bring charges following an Foreign Corrupt Practices Act (FCPA)-related investigation, the protracted...more

7/3/2015 - Africa Bank Secrecy Act BIS Bribery Construction Industry Contractors Declination DOJ Enforcement Actions FCPA FinCEN France Government Investigations Hotels Mining OFAC Oil & Gas Oil for Food Program PetroTiger Red Notices Suspensions & Debarments UK World Bank

Pushing Deadline for Iran Nuclear Deal, Negotiators Extend Temporary Sanctions Relief for Seven Days

As nuclear negotiations in Vienna reach the targeted June 30, 2015, deadline for an agreement, the P5+1, EU and Iran agreed today to extend the limited and temporary sanctions relief to Iran through July 7, 2015. The...more

7/1/2015 - EU Iran Sanctions Joint Plan of Action JPOA Negotiations Nuclear Weapons P5+1 Nations

State and Commerce Seek Comments on Proposed Export Control Rules Regarding Electronic Transmissions, Defense Services and Other...

On June 3, 2015, the U.S. Department of State’s Directorate of Defense Trade Controls (DDTC) and the Department of Commerce’s Bureau of Industry and Security (BIS) published proposed rules amending the International Traffic...more

6/25/2015 - BIS Cross-Border Defense Sector EAR Export Controls Exports International Data Transfers ITAR Proposed Regulation US Department of State

Red Notice Newsletter - May 2015

Welcome to the May 2015 edition of Red Notice, a publication of Akin Gump Strauss Hauer & Feld LLP. This month on the anticorruption front, a German engineering firm tests Brazil's recently implemented anticorruption...more

6/1/2015 - Bribery Clean Companies Act Cuba Currency Exchange Defense Sector Energy Sector Export Controls FinCEN Germany OFAC Sanctions Serious Fraud Office UK Ukraine Virtual Currency

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