Louis Rothberg

Louis Rothberg

Morgan Lewis

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Executive Order Blocks Property of Those Engaging in Malicious Cyber Activities

The executive order enables US government agencies to block the assets of any foreign person determined to have engaged in malicious cyber-enabled activities....more

4/7/2015 - Barack Obama Blocked Entities Blocked Person Critical Infrastructure Sectors Cyber Crimes Cybersecurity Executive Orders National Security OFAC

Certain Goods and Services Now Eligible for Importation into the United States from Cuba

The U.S. Department of State published its Section 515.582 List that outlines which goods and services produced by independent Cuban entrepreneurs are eligible for importation into the United States....more

3/5/2015

SEC Recommends "Localized" FCPA Controls For Foreign Subsidiaries

The SEC investigation found that the respondent lacked sufficient internal controls to prevent and detect approximately $230,000 in improper payments made by its China-based offices that falsely recorded the payments in books...more

3/5/2015

Partial Relaxation of Cuban Sanctions: New Regulations Issued

The U.S. Department of the Treasury and the U.S. Department of Commerce have released new regulations that loosen restrictions on trade and travel with Cuba....more

1/21/2015 - Amended Regulation Banking Sector Barack Obama BIS CACR Cuba Embargo Executive Orders Export Controls Exports Imports OFAC Sanctions Telecommunications Trade Relations Travel Permits U.S. Commerce Department U.S. Treasury

OFAC Sanctions Compliance Provisions in Various Agreements

Due to costly settlements secured by U.S. regulatory agencies, banks, insurers, and corporations are increasingly inserting rigorous OFAC sanctions compliance language into their credit agreements, insurance policies,...more

1/16/2015 - Banks Chief Compliance Officers Commercial Insurance Policies Compliance Contract Drafting Counterparty Risk Insurance Companies Loan Agreements OFAC Purchase Agreement Sanctions Underwriting Agreements

President Obama's New Executive Order Blocks Trade to Crimea

The executive order bans the export of goods, technology, and services to the Crimea region of Ukraine, but that’s not all it does. On December 19, 2014, U.S. President Barack Obama issued Executive Order #13685,...more

1/16/2015 - Crimea Executive Orders Export Controls Licenses OFAC Ukraine

President Obama Announces Sweeping Changes to United States’ Diplomatic Relationship with Cuba

No changes in connection with the U.S. – Cuba embargo and sanctions will be effective until OFAC and the Commerce Department formally revise their respective regulations and general licenses to implement the President's new...more

12/19/2014 - Barack Obama Cuba Embargo Foreign Relations Sanctions

New Senate Bill Significantly Expands U.S. Sanctions Against Russia

The bill, if passed, would impose severe sanctions on “foreign persons” that make significant investments in Russian crude oil projects....more

12/10/2014 - Arms Export Control Act Banking Sector Defense Sector Export Controls Exports Foreign Investment Foreign Nationals Oil & Gas Pending Legislation Russia Sanctions

OFAC Sanctions Compliance Provisions in Agreements

Due to costly settlements secured by U.S. regulatory agencies, banks, insurers, and corporations are increasingly inserting rigorous OFAC sanctions compliance language into their credit agreements, insurance policies, and...more

12/4/2014 - Acquisition Agreements Banks Compliance Contract Drafting Counterparty Risk Credit Agreements Insurers OFAC Sanctions

OFAC Settlement Extends Violations to “Support Service” Providers

OFAC stated that an insurance company and its affiliates violated OFAC regulations by providing insurance support services for policies that were issued to, or provided coverage for, persons designated on the OFAC Specially...more

11/4/2014

Revised OFAC Guidance on "Shadow" SDNs

OFAC expands the scope of its 50% rule. On August 13, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued “Revised Guidance on Entities Owned by Persons Whose Property and Interests in...more

8/25/2014 - Asset Freeze Blocked Entities Blocked Person Fifty Percent Rule OFAC SDN List U.S. Treasury

U.S. Department of Commerce Implements New Russian Oil and Gas Sanctions

The sanctions directly affect companies involved in Russia's oil and gas industries by imposing new export license requirements....more

8/7/2014 - BIS Export Administration Regulations Export Controls Exports Licensing Rules OFAC Oil & Gas Russia Sanctions SDN List U.S. Commerce Department Ukraine

Temporary Iran Sanctions Relief

Relief is very limited and alleviates threat of sanctions regarding transactions by non-U.S. or foreign persons. On January 30, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published...more

2/7/2014 - Foreign Policy Iran Iran Sanctions OFAC U.S. Treasury

New Export Control Changes Affect Naval Warfare and Ground Vehicles

Second phase of the Export Control Reform Initiative allows certain U.S. industries to fall into categories that may make them more attractive to foreign buyers. On January 6, the Obama administration reached another...more

1/16/2014 - Export Controls Exports ITAR US Munitions List

Export Control Changes Affecting Aircraft Industry Take Effect

New rules allow some aircraft-related items to fall into categories that may make them more attractive to foreign buyers. On October 15, the Obama Administration reached an important milestone of the president’s Export...more

11/14/2013 - Aircraft Export Controls Exports ITAR US Munitions List

SEC Reporting for Certain 2012 Iran-Related Transactions

Mandatory requirements cover actions of issuers' foreign subsidiaries and affiliates. On August 10, 2012, section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012 (the Act), 112 P.L. 158, added new...more

1/23/2013 - Foreign Subsidiaries Iran Threat Reduction and Syria Human Rights Act OFAC Reporting Requirements SEC Subsidiaries

New OFAC Regulations Implement Iranian Sanctions

Grace period through March 8 provided to foreign subsidiaries to wind down Iranian transactions. On December 26, 2012, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) amended the Iranian...more

1/9/2013 - Iran Threat Reduction and Syria Human Rights Act ITSR OFAC Subsidiaries

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