Margaret Gatti

Margaret Gatti

Morgan Lewis

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Iran Secondary Sanctions Relaxation: Effect on Shipping and Related Activities

Shipping companies should be mindful of restrictions that still apply. The relaxation of Iran sanctions that the United States implemented on January 16, 2016—“Implementation Day” for the Joint Comprehensive Plan of...more

2/23/2016 - Foreign Entities Foreign Persons Implementation Day Iran Sanctions Joint Comprehensive Plan of Action (JCPOA) Shipping Visas

US and EU Iran Sanctions Relief: What Non-US Persons Need to Know

Even in light of EU and US relaxation of sanctions against Iran after Implementation Day, non-US Persons should evaluate any proposed dealings with Iran to make sure such activities do not violate any new or continuing...more

1/26/2016 - EU Export Controls Foreign Affiliates Foreign Entities General Licenses Implementation Day Iran Iran Sanctions Joint Comprehensive Plan of Action (JCPOA) OFAC SDN List Visa Waiver Program

“Implementation Day” Arrives, Triggering Relaxation of US Sanctions against Iran

The impact of Implementation Day will vary depending on whether you are a US Person, a US-owned or controlled Foreign Entity, or a Foreign Person with no US nexus—what’s your status? ...more

1/20/2016 - Exports Foreign Entities Implementation Day Imports Iran Sanctions Joint Comprehensive Plan of Action (JCPOA) Licensing Rules OFAC SDN List

SOLAS Convention Container Weight Verification Requirements Arrive Sooner Than You Think

Beginning July 1, 2016, the SOLAS Convention will require the shipper of a packed export container to verify the container’s weight before it is loaded aboard a ship. In November 2014, the International Maritime...more

1/7/2016 - Exports International Treaties Maritime Transport Safety Precautions Shipping Cargo Verification Requirements Vessels

US Government Further Relaxes Trade Restrictions with Cuba

However, the new transaction rules leave the embargo largely in effect. Early this week, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Department of Commerce’s Bureau of Industry and...more

9/23/2015 - BIS Cuba EAR Embargo Exporters Exports Financial Transactions Foreign Bank Accounts Imports International Travel Internet Obama Administration OFAC Office Space Online Education Sanctions Services Shipping Telecommunications Trade Restrictions Travel U.S. Commerce Department U.S. Treasury Warehouses

State Sponsor of Terrorism Amendment Made to EAR Regarding Cuba

Amendment triggers change in EAR de minimis level for controlled US-origin content in foreign made products. On April 14, US President Barack Obama submitted to Congress the statutorily required report indicating the...more

9/3/2015 - Barack Obama Cuba De Minimus Quantity Exemption Embargo Export Administration Regulations Export Controls Exports ITAR State Sponsors of Terrorism U.S. Commerce Department

Switzerland Is the First Country to Lift Some Sanctions on Iran

Certain US sanctions on Iran may be lifted mid to late 2016 or even later. On August 13, Switzerland became the first country to formally lift certain sanctions on Iran, following the announcement of the Iran nuclear...more

8/17/2015 - Executory Contracts Implementation Day Iran Iran Sanctions Non-US Entities Nuclear Power OFAC Switzerland

Joint Plan of Action Regarding Iran's Nuclear Program Announced

US sanctions are not immediately lifted due to the announcement. On July 14, the United States, European Union, United Kingdom, France, China, Russia, and Germany (P5+1/E3/EU+3 countries) and Iran reached a Joint...more

7/16/2015 - Banking Sector Energy Sector EU Executory Contracts Financial Institutions Foreign Relations IAEA Inspections Iran Iran Sanctions Joint Comprehensive Plan of Action (JCPOA) Nuclear Power Nuclear Weapons P5+1 Nations Presidential Veto Trade Relations U.S. Person UN Security Council United Nations

Trade Bills Continue to Forge Ahead to the Finish Line

On May 14, the Senate passed customs reauthorization trade preference legislation and gave an affirmative cloture vote for the Trade Promotion Authority Act and the Trade Adjustment Assistance program. As part of a...more

5/18/2015 - AGOA Customs Generalized Scheme of Preferences GSP Regime Haiti Trade Adjustment Assistance Trade Agreements Trade Promotion Agreements

Customs-Trade Partnership Against Terrorism Officially Opening to Exporters

US Customs and Border Protection will open enrollment to exporters for the first time next week. On May 17, exporters will be eligible to participate in the Customs-Trade Partnership Against Terrorism program (C-TPAT)....more

5/14/2015 - C-TPAT Customs and Border Protection Exporters

US/Cuba Relations: What You Need to Know About Protecting US Brands in Cuba

Recent developments justify reconsidering companies’ trademark protection options. Although US sanctions that generally prohibit US exports to Cuba as well as other transactions that involve Cuba largely remain in...more

5/12/2015 - Corporate Counsel Cuba Cuban Assets Control Regulations (CACR) Exports OFAC Trade Relations Trademarks

Informed Compliance Period Comes to Its Imminent End for Importer Security Filing

CBP will be increasing enforcement of violations effective May 14, 2015. On May 14, the informed compliance period for Importer Security Filing (ISF) will come to an end and Customs and Border Protection (CBP) will...more

5/11/2015 - Customs and Border Protection Enforcement Filing Requirements Importers Ports

Commerce’s Direct Investment Surveys: Do You Need to File a BE-10?

This year marks the return of the BE-10, the five-year benchmark survey of US direct investment abroad—as a result, US companies that have an ownership or voting interest of 10% or more in a foreign business enterprise may be...more

4/30/2015 - Benchmarks Foreign Investment Form BE-10 U.S. Commerce Department

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


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


CBP Holds “Misidentified” Importer Liable for 216% of Antidumping Duties

In late 2014, U.S. Customs and Border Protection denied an importer of record’s protest that claimed that it was incorrectly held liable for the payment of antidumping duties assessed on furniture from the People’s Republic...more

2/2/2015 - Anti-Dumping Duty China Countervailing Duties Customs and Border Protection Furniture Industry Importers Sanctions U.S. Commerce Department

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 Industry 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 Insurance Industry OFAC Sanctions

Making a “Made in the USA” Claim Requires a Reading of Federal and State Law

Given the rise in false advertising claims, manufacturers and retailers that wish to label or advertise their goods as being “Made in the USA” must be aware of federal and state laws that place certain requirements on the...more

11/9/2014 - Advertising Corporate Counsel Country of Origin False Advertising FTC Labeling Manufacturers Popular Regulatory Standards Retail Market

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


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