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PayPal To Pay Dearly for Alleged Violations of OFAC Sanctions

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has announced a $7,658,300 settlement with PayPal, Inc. (PayPal) to resolve potential civil liability for 486 alleged violations of the Iranian,...more

UK Regulator Announces Its Approach to Financial Promotions in Social Media

On March 13, the UK regulator, the Financial Conduct Authority (FCA) published finalized guidance on its supervisory approach to financial promotions in social media (the “Guidance”). The range of social media within the...more

UK’s Financial Services Regulator: No Hashtags in Financial Promotions

Earlier this month the UK’s financial services regulator, the Financial Conduct Authority (FCA), issued its final guidance on financial promotions made via social media channels. As we reported last year, the FCA...more

Restrictions Eased for Communications-Related Items Exported to Sudan

On February 18, 2015, in a coordinated action, the Commerce Department's Bureau of Industry and Security (BIS) and Treasury Department's Office of Foreign Assets Control (OFAC) announced and implemented changes to the...more

International IT Companies Face Continuing Headwinds in China

Our September 16, 2014 client alert, “Brave New World? Recent Challenges Facing Foreign IT Companies in China,” discussed efforts by the Chinese government to enforce heightened network security standards, with a particular...more

Commercializing Financial Products to Retail Clients in Belgium

On 12 June 2014, the Royal Decree of 12 April 2014 regarding certain information requirements governing the commercialization of financial products to non-professional (retail) clients was published in the Belgian Official...more

Telecommunications in Cuba and the U.S. Embargo: History, Opportunities, and Challenges

Since President Obama announced the United States’ new policy to normalize relations with Cuba, talk about opportunities for U.S. telecommunications companies has flourished. That reaction only intensified when the Treasury...more

Cuba Today

One week ago, I visited Cuba with a delegation from the American Bar Association’s International Law Section. During our visit, we met with government officials, attorneys, law professors, foreign businessmen, journalists...more

EBA Opinion on Regulation of EU Lending-Based Crowdfunding

On February 26, 2015, the European Banking Authority (“EBA“) published an opinion on lending-based crowdfunding. The opinion notes that certain Member States (France, Italy, Spain and the UK) have created specific regulations...more

Cuba Sanctions: 10 Important Changes

Ten key changes to US sanctions and export regulations for Cuba. On January 15, 2015, the Departments of the Treasury and Commerce revised the Cuban Assets Control Regulations (CACR) and the Export Administration...more

FCPA Compliance and Ethics Report-Episode 130, The Oscars and Compliance, Part IV with Jay Rosen [Video]

In this Part IV of my continued exploration of the Oscars and compliance with Jay Rosen, we look at the touchpoint which Hollywood and the movie industry has which might subject it to FCPA liability. ...more

China’s New Policy for Foreign Investment in E-Commerce - Shanghai Free Trade Zone Opens Door for Complete Foreign Ownership in...

Further to the early 2014 policy that relaxed the restrictions on the foreign equity ratio in value-added telecommunications business in the Shanghai Free Trade Zone (“Shanghai FTZ”), on January 15, 2015, the Ministry of...more

2015: A New Agenda for Europe

Every year, the European Commission (the Commission) adopts a plan of action for the next 12 months. The Work Programme for 2015 is the first one to be presented by the Juncker Commission. It translates into concrete actions...more

Shifting Course: Expanding the Scope of Permissible Cuba Transactions

The Treasury Department’s Office of Foreign Assets Control (“OFAC”) has issued its first set of amendments to the Cuban Assets Control Regulations (“CACR”) to begin implementing a major policy shift in United States–Cuba...more

New Opportunities in Cuba for U.S. Travel and Medical Companies – Cigars but not Commerce

After President Obama's announcement that his Administration will pursue a policy aimed at improving U.S.-Cuba diplomatic relations and ultimately eliminating the economic embargo on Cuba, the U.S. Treasury and Commerce...more

Important Changes to the U.S. Sanctions Against Cuba

The Obama administration recently announced the most significant changes in years to U.S. sanctions against Cuba, allowing expanded travel, trade, and exchange in targeted areas....more

U.S. Government Implements Cuba Policy Changes

On January 16, 2015, the Office of Foreign Assets Control, U.S. Department of the Treasury (“OFAC”), and the Bureau of Industry and Security, U.S. Department of Commerce (“BIS”), each published regulations implementing the...more

China removes foreign investment cap on e-commerce business in the Shanghai free trade zone

The PRC Ministry of Industry and Information Technology (MIIT) announced on January 13, 2015 that effective the same date, the investment ratio restriction for foreign investment in e-commerce business (falling under the...more

Cuba Regulations Change – Round 1

In today’s Federal Register, both the Office of Foreign Assets Control (OFAC) and the Bureau of Industry and Security (BIS) published the first revisions to the U.S.’ Cuba economic sanctions. As expected, those changes...more

Treasury and Commerce loosen Cuba embargo

In implementation of the policy changes announced by President Barack Obama on December 17, 2014, the US Department of the Treasury, Office of Foreign Assets Control (OFAC) has amended the Cuban Assets Control Regulations, 31...more

The Obama Administration Revises the Cuba Sanctions Regulations to Expand Trade Opportunities While Certain Law Makers Question...

On January 15, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) released important updates to the Cuban Assets Control Regulations (“CACR”). The U.S. Department of Commerce’s Bureau of Industry...more

Treasury Department Eases Cuba Sanctions

New Rules Open Opportunities for Exports, Financial Services, and Travel- On January 16, 2014, the U.S. Treasury Department issued new sanctions regulations easing the 54-year old Cuban embargo. Coming in the wake of...more

Where the Rubber Meets the Road: Obama Administration Announces Regulatory Amendments to U.S. Cuba Sanctions

On January 16, 2015, the U.S. Department of the Treasury (“Treasury”) amended the Cuban Assets Control Regulations, 31 C.F.R. Part 515 (“CACR”), and the U.S. Department of Commerce amended the Export Administration...more

FCPA Compliance and Ethics Report-Episode 124, The Oscars and Compliance, Part I with Jay Rosen [Video]

In this episode I begin a five-part series on the Oscars and Compliance with recovering Hollywood screenwriter Jay Rosen. In this Part I, we review the process by which films are nominated for the Oscars and the campaigns...more

Partial Relaxation of Cuban Sanctions: New Regulations Issued

The U.S. Department of the Treasury and the U.S. Department of Commerce have released new regulations that loosen restrictions on trade and travel with Cuba....more

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