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Today, President Trump Decertified the Iran Deal and Announced Tougher Sanctions on Iran

What does decertification mean? For the time being, decertification is a solely U.S. issue. Under the Iran nuclear agreement (known as the Joint Comprehensive Plan of Action, or JCPOA), Iran agreed to limits on its nuclear...more

North Korea Sanctions Continue to Intensify

On September 11, 2017, the UN Security Council unanimously imposed new sanctions on North Korea. The move came only days after Pyongyang launched an underground nuclear test that may have been the detonation of a hydrogen...more

Growing Pains for Expanding Tech Companies: Uber Investigated for FCPA Violations

On August 29, it was announced that the U.S. Department of Justice is considering an investigation into Uber, the San Francisco-based technology company that has expanded its ride-sharing service abroad to more than 70...more

One Year From Now, You May Be Out of Iran: Trump Administration Policy and the Timeline for Snapback

On July 17, 2017, the U.S. State Department certified that Iran continues to meet the conditions of the Iran nuclear agreement known as the Joint Comprehensive Plan of Action, or JCPOA. As a result, for the next 90 days, the...more

Our Cuba Sanctions Predictions: How Did We Do?

In our last post, we made a few cocky predictions about the new Trump Administration’s Cuba policy. We correctly asserted that the President would try to chart a narrow course between the Scylla of conservative Cuban-American...more

6/23/2017  /  Cuba , Embargo , OFAC , Sanctions , Travel Restrictions

Our Armchair Santería on Cuba Policy: What Will President Trump do on Cuba?

According to reports published this week, the Trump Administration is preparing to release the results of its policy review on Cuba in the “coming weeks.” We don’t have a crystal ball (or a leaking insider). But we continue...more

Predicting the Unpredictable: Will President Trump Tear Up the Iran Nuclear Deal?

As a candidate for President, Donald J. Trump was widely reported to despise the Iran nuclear agreement, which is known as the Joint Comprehensive Plan of Action. As President, he responded to reports of Iranian missile tests...more

Predicting the Unpredictable: Will Tariffs Under President Trump Cause a Trade War With China?

President Trump has stated that he would impose tariffs on imports from China ranging from ten to forty-five percent. Can he do it? And will it cause a trade war? The Effects of Increased Tariffs - In the 18th...more

Negotiation By Tweet: The Uncertain Future of U.S.-Cuba Relations

After the announcement of Fidel Castro’s death on November 26, 2016, President Barack Obama sent a message to the Cuban people highlighting his administration’s efforts to improve relations between the United States and Cuba....more

The Future of the U.S.-Canada Trade Relationship in Light of the Election

The United States and Canada enjoy a unique bilateral relationship. That relationship reflects a unique friendship, underpinned by shared geography, similar values, common interests, deep connections and powerful,...more

Those Three Little Words: OFAC’s Subtle Language Shift Could Create Sweeping Change on Iran Investment

Article Highlights: - Non-U.S. banks can do business with Iran and continue their relationships with U.S. banks. - Non-U.S. companies may use proceeds from Iran transactions more freely, including in the United...more

Layover in Tehran: United States Authorizes Carriers to Land Civil Aircraft in Iran

On July 29, 2016, the U.S. Treasury Office of Foreign Assets Control (OFAC) cleared the runway for non-U.S. operators of civil aircraft to send flights into Iran. New “General License J” authorizes many Boeing, Airbus, and...more

The Revival of the Age of Antidumping and Countervailing Duty Cases

For the first time since the era of pagers, dial-up, and Y2K hysteria, U.S. trade remedy cases are experiencing a resurgence. Under U.S. law, U.S. producers of goods may petition the U.S. government to impose extra tariffs on...more

Flying the Too-Friendly Skies? Europe Opens Routes for Sanctioned Iran Airline

On June 20, 2016, you will be able to take a non-stop flight from Tehran to Paris . . . but you probably shouldn’t. According to its website, the Iranian airline Mahan Air will add the City of Lights to the list of...more

New Business Opportunities in Iran! Who Will Be Your Banker? Non-U.S. Banks Hesitant to Process Lawful Iran Transactions…and for...

- Sanctions relief presents new business opportunities with Iran - Most U.S. companies are still prohibited from Iran business, but the U.S. government is encouraging lawful business by non-U.S. companies - The...more

The Day of North Korea Sanctions: the UN Imposes the Toughest North Korea Sanctions Yet While OFAC and State Designate More North...

After weeks of negotiations and a Putin-backed delay, the UN Security Council unanimously adopted resolution 2270 on March 2, 2016, imposing new sanctions against North Korea. According to U.S. Secretary of State John Kerry,...more

US and EU Iran Sanctions Lifted: How to Proceed in the Aviation Sector?

On 16 January 2016, the United States and the EU lifted certain sanctions against Iran in compliance with the Joint Comprehensive Plan of Action (JCPOA) agreed among Iran, China, France, Germany, the Russian Federation, the...more

The Schrems Decision: How the End of Safe Harbor Affects Your FCPA Compliance Plan

Like a needle to a balloon, the Schrems decision has drastically altered the data privacy landscape. Who is affected? Everyone – consumers, corporations, employees. But who needs to take action? Any company with offices in...more

Iran Nuclear Deal Clears Senate Obstacle, But Will “Snap-Back” Bite?

On Thursday, September 10, 2015, U.S. Senate Democrats cleared a hurdle for the proposed Iran nuclear agreement by blocking a Senate resolution that would have rejected the deal. The result, in which Senate Republicans...more

A Break From the Past: Historic Deal with Iran Marks A New Day in U.S.-Iran Relations

Today, President Obama announced a landmark agreement with Iran designed to prevent Iran from obtaining a nuclear weapon in exchange for lifting sanctions that have retarded the country’s development for the decades since the...more

America Turns A Page: Cuba Removed From U.S. List of State Sponsors of Terrorism

The United States officially removed Cuba from its list of State Sponsors of Terrorism today, according to an announcement by the U.S. State Department via Twitter. The change takes effect immediately, according to the...more

A Carriage of Justice: Obama to Remove Cuba from Terrorist Sponsor List

In a move that may honestly mean more to America than to Cuba, the White House has announced that President Obama will remove Cuba from the U.S. list of “State Sponsors of Terrorism.” The U.S. Department of State has listed...more

Update: Iran Nuclear Deal

Iran and the Western powers have agreed to agree again. On April 2, 2015, the so-called P5+1 (the United States, the UK, China, France, and Russia) along with the EU, have joined Iran in announcing that they have reached a...more

10 Things You Didn’t Know You Could Import From Cuba

One aspect of the dramatic shift in U.S. policy toward Cuba that has not been widely reported is a relaxation of the old rule prohibiting imports of most Cuban goods and services. Under the new rules, if your Cuban supplier...more

OFAC Issues Cuban Asset Control Regulations Focused on the U.S. Financial Sector

On January 15, 2015, the Department of Treasury’s Office of Foreign Assets Control (OFAC) amended the Cuban Assets Control Regulations to implement changes in U.S. policy toward Cuba announced by President Obama on December...more

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