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President Trump Announces Rollback on Obama-era Cuba Sanctions Easing

Changes to unwind will not take effect until new regulations are issued. On June 16, US President Donald Trump announced his decision to revoke some—but not all—of the relaxations in Cuba sanctions initiated under former...more

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

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

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

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

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

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

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

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

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

“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

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

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

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

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

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

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

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

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

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

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

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

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
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