Margaret Gatti

Margaret Gatti

Morgan Lewis

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New Documentary Requirements Issued for Hong Kong Exports and Reexports

Effective April 19, 2017, US exporters intending to export certain controlled items to Hong Kong will need to obtain, prior to shipment, either a copy of a Hong Kong import license or a statement issued by the Hong Kong...more

3/23/2017 - BIS EAR Exporters Exports Final Rules Hong Kong Imports Licenses

Legal Bases for Iran Sanctions, Cuba Sanctions, and NAFTA

How easily can the Trump administration change the status quo? The International Emergency Economic Powers Act (IEEPA), 50 U.S.C §§1701-1707 enacted October 28, 1977, authorizes the US president to broadly regulate...more

1/4/2017 - Cuba Executive Orders International Emergency Economic Powers Act (IEEPA) Iran Iran Sanctions NAFTA Sanctions Trump Administration

New York Mandates Economic Sanctions Compliance Program

The New York rule became effective January 1, 2017. The New York State Department of Financial Services (DFS) has issued a regulation that requires certain New York regulated financial institutions to maintain programs...more

1/3/2017 - BSA/AML Compliance Department of Financial Services Economic Sanctions Financial Institutions OFAC

US Imposes New Sanctions on Russia for Cyber-attacks

Five entities and six individuals were sanctioned for interference with the 2016 US election. On December 29, 2016, President Obama issued a new executive order that expands the authority of the US Secretary of Treasury...more

1/3/2017 - Cyber Attacks Executive Orders Presidential Elections Russia Sanctions

Considerations for Travel to Iran to Explore Relaxed Trade Opportunities

Before booking your airfare, be mindful of these potential issues. In light of liberalized trade with Iran made possible by the Office of Foreign Assets Control’s (OFAC’s) General License H and the relaxation of US...more

9/2/2016 - Arrest Business Opportunities DHS Dual Citizenship International Travel Iran Iran Sanctions OFAC Trade Options Travel US Department of State Visa Waiver Program Visas

Export Regulation Revisions: Harmonization of Destination Control Statements

New rules synchronize Destination Control Statements for EAR and ITAR. On August 17, both the US Commerce Department’s Bureau of Industry and Security (BIS) and the US State Department’s Directorate of Defense Trade...more

8/22/2016 - BIS DDTC EAR Export Controls ITAR US Department of State

IRS Publishes List of Countries Requiring Cooperation with an International Boycott

Non-listed countries can also present compliance issues under both IRS and Commerce Department Requirements. On August 5, the US Department of the Treasury’s Internal Revenue Service (IRS) published in the Federal...more

8/19/2016 - Boycotts Cooperation Criminal Prosecution IRS Israel OFAC U.S. Commerce Department U.S. Treasury

OFAC Cites Violations in Dealings with Specially Designated Nationals

Insurance companies and financial institutions are targeted. On August 2, the US Department of the Treasury's Office of Foreign Assets Control (OFAC) issued a Finding of Violation against two different insurance...more

8/5/2016 - Banks Financial Institutions Foreign Narcotics Kingpin Sanctions Global War on Terror (GWOT) Health Insurance Insurance Companies Iran Sanctions OFAC SDN List

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

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