Office of Foreign Assets Control

News & Analysis as of

Post-Election Update on Cuba

New Administration’s Cuba Policy Plans - Prior to President Trump’s inauguration, and in an effort to continue normalizing U.S.-Cuba relations, President Obama ended the "wet-foot, dry-foot" policy which since 1995 has...more

Financial Services Report - Spring 2017

EDITOR’S NOTE - In like a lion, out like a lamb—it works for weather; does it work for new administrations? We’ll have to wait and see. We’ll have to wait and see about the length of CFPB Director Richard Cordray’s...more

ZTE Settlement Highlights Broad Extraterritorial Application of U.S. Sanctions and Export Controls to Non-U.S. Companies

On March 7, U.S. authorities settled criminal and civil proceedings involving Zhongxing Telecommunications Equipment Corporation and certain of its affiliates ("ZTE"). ZTE is the largest publicly traded telecommunications...more

From Obama to Trump – Sanctions Roundup

The Office of Foreign Assets Control (OFAC) of the U.S. Department of Treasury has issued several significant updates to various sanctions programs over the last several weeks. Beginning during President Barack Obama’s last...more

ZTE Pays the Price for Circumventing Sanctions and Export Controls

Here is a real zinger – clients sometimes do not tell their lawyers the truth. I will wait a minute while you get off the floor because I know everyone is shocked and amazed that this happens. But in the recent ZTE case,...more

ZTE Is Assessed $1.19 Billion in Penalties for Criminal and Civil Violations of Export Control and Economic Sanctions Laws and...

On March 7, 2017, the U.S. government announced that China's Zhongxing Telecommunications Equipment Corporation and its affiliate, ZTE Kangxun Telecommunications Ltd. (collectively "ZTE"), have agreed to a global settlement...more

"US Announces Record-Setting Penalties for Violations of Export Controls and Economic Sanctions"

On March 7, 2017, the United States announced that China’s Zhongxing Telecommunications Equipment Corporation and ZTE Kangxun Telecommunications Ltd. and their respective affiliates (collectively, ZTE) had agreed to a record...more

Three Important Lessons to Be Learned from the $1.2 Billion ZTE Settlements

On March 7, we learned that Zhongxing Telecommunications Equipment Corporation (ZTE) concluded 3 settlement agreements that could result in penalties as high as $1.2 billion for its violations of U.S. sanctions and export...more

Private Equity and the New Trump Administration: Your Top Ten Questions Answered

The election of President Trump contained more than a few positive signs for Private Equity (PE) firms. Promises of a lower corporate tax environment, a ten-percent tax holiday for funds parked overseas, large infrastructure...more

Red Notice Newsletter - February 2017

Acting SEC Chief Limits Subpoena Authority to Enforcement Division Acting Director - On February 15, 2017,The Wall Street Journal reported that the acting Chair of the Securities and Exchange Commission (SEC), Michael...more

New Administration Ramps up Enforcement Efforts

The Trump administration has vowed to bring jobs back to the states. One of the methods it appears it’ll take advantage of is continued, aggressive enforcement of U.S. laws governing exports and international conduct....more

New York Implements New BSA/AML/OFAC Certification and Monitoring/Filtering Regulation for Banks and Money

Financial firms that are chartered or licensed to do business in New York should be aware of an important new regulation that became effective on January 1, 2017. Money laundering and terrorist financing are generally thought...more

OFAC Increases Civil Monetary Penalties

On February 10, 2017, the U.S. Treasury Department announced an increase in civil monetary penalties across a number of Treasury offices, including the Office of Foreign Assets Control (OFAC). Understanding the potential...more

Changes to Sudanese Sanctions Program Could Benefit U.S. Life Sciences Companies (A Little)

On January 13, 2017, President Obama signed the Executive Order “Recognizing Positive Actions by the Government of Sudan and Providing for the Revocation of Certain Sudan-Related Sanctions” that revoked many U.S. economic...more

Federal District Court Rebuffs Attempt by Navy Sailors to Satisfy Judgment Against Republic of Sudan by Attaching Assets Held by...

A recent decision by the United States District Court for the Southern District of New York delivered a victory to banks seeking to prevent judgment creditors from attaching assets “blocked” pursuant to Office of Foreign...more

Kingpin Act Wielded Against Vice President of Venezuela

The Executive Vice President of Venezuela, Tareck Zaidan El Aissami Maddah (El Aissami), was designated on Monday by the U.S. Department of Treasury as a Specially Designated Narcotics Trafficker under the Foreign Narcotics...more

New Iran Designations: OFAC Adds 25 Persons to the SDN List in Response to Iran’s Ballistic Missile Test

On February 3, 2017, the U.S. Office of Foreign Assets Control (OFAC) added 25 persons to its List of Specially Designated Nationals and Blocked Persons (the SDN List, and every person thereon, an SDN) as a result of their...more

OFAC Authorizes Certain Dealings with Russian Security Agency

In its first public statement since the inauguration, the US Department of Treasury’s Office of Foreign Assets Control (OFAC) announced on February 2, 2017, that it had authorized limited dealings with the Federal Security...more

Trump Administration Takes Moderate Steps Against Iran. What Comes Next?

On Friday, February 3, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) announced it was designating 25 entities and individuals as Specially Designated Nationals (SDNs) for their involvement in...more

Another Reason To Always Run Compliance Screenings Even If You Are A Non-U.S. Party – OFAC Is Targeting Foreign Companies

If you are a foreign company that wants access to the U.S. financial markets, make sure you understand the U.S. Iran Transactions and Sanctions Regulations (ITSR). Administered by the U.S. Department of Treasury’s Office of...more

Trump Administration Makes First Iran Sanctions Designations

Key Points - - The U.S. Department of the Treasury’s Office of Foreign Assets Control has added 25 new entities and individuals to its Specially Designated Nationals List, including some located in China, Lebanon,...more

White Collar Enforcement and the New Trump Administration: Your Top Ten Questions Answered

Enforcement activity under the Obama administration often made headlines for the eye-popping level of fines, with the Foreign Corrupt Practices Act (FCPA), Anti-Money Laundering (AML) regulations, and economic sanctions...more

Presidential “Notice” Triggers New Iran Sanctions Designations

On February 3, 2017, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of the Treasury added twenty-five individuals and entities to its Specially Designated Nationals (“SDN”) List. According to the White...more

Highlights of the ACI Admiralty and Maritime Claims and Litigation Conference in Miami

Last week I had the pleasure of co-hosting the ACI Admiralty and Maritime Claims and Litigation conference with my friend and colleague Chris Nolan from Holland & Knight. Here are a few highlights from the conference: -...more

Red Notice Newsletters - Chinese

ANTICORRUPTION DEVELOPMENTS - Las Vegas Sands Corporation Agrees to Pay Approximately $7 Million to Resolve DOJ FCPA Enforcement Action – On January 19, 2017, Las Vegas Sands Corporation (“Sands”), a Nevada-based...more

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Cybersecurity

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