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A New Latitude: Charting a Course for Cuba

Today President Barack Obama made a stunning speech announcing steps the United States will take to reduce U.S. sanctions against Cuba. The announcement followed the release of two U.S. citizens held by the Cuban government....more

12/18/2014 - Barack Obama Cuba Foreign Relations

Military Electronics Export Reform: Let the Chips Fall Where They May

Every time there is a new round of reforms under the President’s Export Control Reform initiative, we hear the same advice: - Controls on certain items are eliminated or reduced (which creates new opportunities for...more

12/8/2014

New U.S. Restrictions on Russia: OFAC Guidance and Industry-Specific Sanctions

OFAC Expands the 50 Percent Rule - Last month, the Department of Treasury’s Office of Foreign Assets Control (OFAC) released new guidance related to entities owned or controlled by persons designated as a Specially...more

9/19/2014 - Foreign Policy OFAC Russia Sanctions

Shedding Light on CFIUS: Appeals Court Holds That CFIUS Review Lacks Constitutional Due Process

In a stunning ruling issued on July 15, 2014, the U.S. Court of Appeals for the D.C. Circuit held that review by the Committee on Foreign Investment in the United States (“CFIUS”) and the subsequent unwinding of the...more

7/21/2014 - CFIUS Due Process Fifth Amendment Foreign Investment

Shelter from the Coming Storm: Anti-Corruption Compliance in European Public Procurement

A red sky at morning is the traditional harbinger of ill weather. From our vantage point in Brussels, we’ve scanned the horizon for signs of the future of anti-bribery enforcement activity in Europe. We’ve identified four...more

7/17/2014 - Anti-Corruption Enforcement EU European Commission Transparency

Russian Against Time: New Sanctions and Lowered Expectations as Ukraine Crisis Continues

There’s no end in sight for the turmoil in Ukraine. And there’s no end in sight for international sanctions against Russia for causing that turmoil. As sanctions escalate, so will the collateral damage. New sanctions...more

5/2/2014 - Foreign Policy Russia Sanctions Ukraine

The Gloves are Off: U.S. Sanctions Block Aggressors in Crimea

In response to Russia’s military presence in the Crimean region of Ukraine, President Obama issued an Executive Order (“EO”) on March 6, 2014, authorizing the blocking of property of individuals and entities involved in the...more

3/11/2014 - Executive Orders Financial Crimes Foreign Banks Russia Sanctions U.S. Treasury Ukraine

Dodd-Frank Whistleblower Protection: For America Only

The U.S. District Court for the Southern District of New York has held that the whistleblower protection provisions of the Dodd-Frank Act do not apply outside the United States, even where the employee alleged he was...more

11/14/2013 - Anti-Retaliation Provisions Dodd-Frank Extraterritoriality Rules FCPA Whistleblower Protection Policies Whistleblowers

Politics and Consequences: An Update on U.S. Sanctions Against Iran

Since Hassan Rouhani’s election to the Iranian presidency, some U.S. leaders have expressed interest in diplomatic talks with Iran. It is currently unclear whether any such talks will ever occur, or on what terms. In the...more

10/11/2013 - FFI Iran Sanctions Medical Devices Middle East OFAC Prescription Drugs

ECR Series Episode VI: The One With Ewoks (And New Rules On Satellites)

This fall, the U.S. Government will finish considering public comments on its draft revision of U.S. Munitions List Category XV, which covers “Spacecraft Systems and Related Articles.” By the end of 2013 (unless delayed by...more

10/10/2013 - Commerce Control List NDAA Satellites U.S. Commerce Department US Munitions List

A Rising Voice on FCPA Compliance: The Court

One FCPA compliance topic we are often asked about by clients is how government investigations start. The U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) have developed a number of mechanisms...more

6/11/2013 - Compliance DOJ FCPA IBM Investigations SEC

Streamlining the System: More Baby Steps Toward Reducing Export Compliance Burdens

Since 2011, President Barack Obama’s administration has actively pursued export control reform designed to reduce the regulatory burdens on U.S. companies and enhance U.S. national security (as reported here). On March 7,...more

4/3/2013 - Barack Obama Commerce Control List Compliance Executive Orders Export Administration Regulations Exports ITAR US Munitions List

New Law To Assess Iranian Activities in the Americas

The U.S. Government has taken yet another step to counter the threat of Iran-sponsored terrorism, this time focusing on Iran’s direct activities in the Western Hemisphere. On December 28, 2012, President Barack Obama signed...more

2/21/2013 - Countering Iran in the Western Hemisphere Act Department of State Terrorist Threats

New Law Expands Scope of Iran Sanctions In New Ways

As the new year brings in a new term for the Obama Administration, the pace of Iran sanctions shows no sign of slowing. As we reported in October and November, Washington’s commitment to denying Iran the ability to advance...more

2/15/2013 - Coal FFI IFCPA Iran Sanctions Metals NDAA OFAC Reinsurance SDN List Shipbuilding Shipping Software Underwriting

What’s In the New FCPA Resource Guide: Some Welcome Clarity and Unexpected Muddling

Much has been said about what is missing from the new FCPA Resource Guide (the Guide) published by the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC). Here, we consider instead the areas in...more

12/6/2012 - Compliance DOJ FCPA FCPA Resource Guide SEC

Iranian Transactions and Sanctions Regulations Impose New Restrictions on U.S. Business in Iran

As we reported last month, the Obama administration continues to display a commitment to increasingly tough sanctions against Iran and its trading partners. Over the past few weeks, the U.S. Department of the Treasury, Office...more

11/20/2012

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