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President Trump Announces New Cuba Policy Restricting Travel and Business with Military-Owned Entities

On 16 June 2017, speaking to a crowd in Miami, Florida, President Trump announced a presidential policy directive strengthening sanctions against Cuba. President Trump stated the imposition of these sanctions was necessary to...more

U.S. Designates New Individuals and Entities for Iran-Related Sanctions

Today, the U.S. Treasury Department, Office of Foreign Assets Control (“OFAC”) imposed sanctions on an additional 13 individuals and 12 entities identified by the Treasury Department as “entities and individuals involved in...more

Smoother Sailing Ahead for Shippers After OFAC Clarifies Cuba Sanctions

On Friday, 6 January 2017, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) revised its Frequently Asked Questions (FAQs), adding five new FAQs (numbers 86-90) pertaining to vessel transactions with...more

1/10/2017  /  Cuba , EAR , Exports , OFAC , Sanctions

OFAC Provides Further Guidance On Iranian Sanctions

This month the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) updated its ‘Frequently Asked Questions Relating to the Lifting of Certain U.S. Sanctions Under the Joint Comprehensive Plan of Action (JCPOA)...more

U.S. Authorities Amend Cuba Sanctions Regulations

On October 17, 2016, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) and the Commerce Department’s Bureau of Industry and Security (BIS) issued new amendments to the Cuban Assets Control Regulations (31...more

U.S. Authorities Roll Back the ‘180-Day Ban’ for Vessels Calling at Cuban Ports

On October 17, 2016, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) and the Commerce Department’s Bureau of Industry and Security (BIS) further eased sanctions against Cuba with a host of new...more

Veterans Affairs to Permit Acquisition of Non-TAA-Compliant Drugs

In a significant policy reversal, the Department of Veterans Affairs (VA) has announced that it will require all covered drugs under the Veterans Health Care Act (VHCA) to be offered on Federal Supply Schedule (FSS)...more

U.S. Government Repeals Crude Oil Export Ban

On December 18, 2015, President Obama signed legislation into law that repeals the 40-year-old U.S. ban on crude oil exports. Congressional leaders agreed to include provisions to repeal the export ban in the Omnibus spending...more

U.S. Customs Ruling Impacts Crude Oil Shipments

U.S. Customs and Border Protection (“CBP”) expanded U.S.-flag requirements in a recent ruling requiring shippers to use costly U.S.-flag vessels when shipping processed condensate to and from a foreign country to be blended...more

Crude Oil Swap Licenses: The Top 10 Things Exporters Need to Know

Recent reports that the Obama administration authorized exports of U.S. light crude oil in exchange for imports of Mexican heavy crude have caused a stir in the industry and a fair amount of confusion in the press. The U.S....more

Reed Smith’s “Crude by Rail” Series - DOT Publishes Amended Regulations for Rail Transport

As part of a 19-month initiative to improve the safety of hazardous rail traffic, on Friday, May 8, 2015, the U.S. Department of Transportation (“DOT”) published new regulations and standards for the bulk transport of Class 3...more

Medical Device Companies Face Severe FCA Penalties for TAA Violations

A spate of recent multi-million dollar settlements has shown that medical device manufacturers are subject to substantial liability under the False Claims Act (FCA) if they misstate the country of origin of their products in...more

BIS Addresses 'Commingling' in Crude Oil Exports

On December 30, 2014, the U.S. Department of Commerce, Bureau of Industry and Security (“BIS”) issued its first-ever published guidance on the Short Supply Controls, the regulations that limit the export of crude oil out of...more

BIS Issues First Published Guidance on the Short Supply Controls

Today, the U.S. Department of Commerce, Bureau of Industry and Security (“BIS”) issued the first-ever published guidance on the Short Supply Controls, the regulations that limit the export of crude oil out of the United...more

1/2/2015  /  BIS , EAR , Export Controls , New Guidance , Oil & Gas

Condensate Exports Raise Compliance Questions for Purchasers

Recent press reports covering the sale and export of lightly processed condensate from the Eagle Ford Shale have characterized such transactions as a major test to the four-decade-long ban on crude oil exports, and a sign...more

‘Country of Origin’ Compliance: The Top 10 Things Pharmaceutical Companies Need to Know

What is the “country of origin” for the drugs you manufacture? This question arises every time a pharmaceutical company labels a drug, imports it, exports it, markets it, or sells it to the U.S. government. Unfortunately, the...more

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