Office of Foreign Assets Control

News & Analysis as of

Changes to Iran Sanctions Provide a Few Business Opportunities, but Many Hurdles

On January 16, 2016, the International Atomic Energy Agency verified that Iran had implemented nuclear reforms negotiated among the United States, the European Union and Iran, a milestone in the agreement referred to as the...more

OFAC Finds "Facilitation" Violation Against Health Product Giant

The Office of Foreign Asset Control (OFAC) reminded the public Thursday of the breadth and danger of the prohibition on "facilitation" of transactions with sanctioned entities and countries and the importance of carefully...more

OFAC Issues Amendments to Cuba Sanctions Regulations

On January 26, OFAC announced amendments to the Cuban Assets Control Regulations (CACR) to further implement policy changes announced by the Obama Administration on December 17, 2014. The regulatory changes will, among other...more

President Obama Highlights TPP, Cuba Embargo in Final State of the Union Address

On January 12, President Obama delivered his seventh and final State of the Union Address to Congress and the American people. Among the many topics that he raised in this annual speech were two trade-related priorities that...more

White House Publishes Third Round of Regulatory Reforms to Cuba Sanctions: 'Musicabana' also Announces Major International Music...

The U.S. Treasury Department's Office of Foreign Assets Control (OFAC) and the Commerce Department's Bureau of Industry and Security (BIS) recently published a series of revisions to the Cuba sanctions regime that appear to...more

"OFAC and BIS Ease Cuba Restrictions With New Amendments"

On January 27, 2016, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Department of Commerce’s Bureau of Industry and Security (BIS) further eased U.S. sanctions and export control regulations...more

Another Shoe Drops: More Changes to the U.S. Cuban Sanctions from the White House

On January 25, the Obama Administration made concurrent announcements about its evolving posture on the Cuban sanctions. On that date, the Office of Foreign Assets Control (OFAC) released more changes to the Cuban Assets...more

Cuba and the United States: A Continuing Shift in Export and Travel Policy

On January 26, 2016, the United States again modified its stance on travel to Cuba and eased certain export restrictions to that country. The changes are not surprising, considering the White House’s determination to...more

Update on Significant DOT, FAA and Other Federal Agencies’ Aviation-Related Regulatory Actions - February 2016

This edition of the Cozen O’Connor Aviation Regulatory Update includes the recently signed U.S.-Mexico bilateral agreement that liberalizes air services between the two countries, new Cuba-related regulations loosening...more

International Trade & Regulatory Advisory: Cuba Update: Latest Changes Signal Expansion of Business Opportunities

On January 26, 2016, as part of the Obama Administration’s ongoing efforts to normalize relations with Cuba, the Department of Commerce, Bureau of Industry and Security (BIS) and the Department of Treasury, Office of Foreign...more

Red Notice Newsletter - January 2016

ANTICORRUPTION DEVELOPMENTS - Convicted Printing Company Ordered to Pay £2.2 Million - On January 8, 2016, the Serious Fraud Office (SFO) announced that Smith & Ouzman Ltd, a U.K. security printing company, was...more

“Implementation Day” Marks Lifting of Certain Nuclear-Related “Secondary” Sanctions on Iran by the United States in Accordance...

On January 16, 2016, the International Atomic Energy Agency (“IAEA”) verified that the Islamic Republic of Iran (“Iran”) had satisfied its commitments under the Joint Comprehensive Plan of Action (“JCPOA”), which was entered...more

US Treasury and Commerce Departments Announce New Changes to Cuba Regulations

On January 25, 2016, the US Treasury Department’s Office of Foreign Assets Control (OFAC) and the US Commerce Department's Bureau of Industry and Security (BIS) announced new changes to existing US sanctions on Cuba,...more

Moving Forward with Iran: An Update on U.S. Business Interests and the Iran Nuclear Settlement

The world reached a critical milestone on January 16, which was “Implementation Day” for the Joint Comprehensive Plan of Action (JCPOA) regarding Iran’s nuclear development program. The JCPOA is the agreement approved on...more

‘Implementation Day’: Key Aspects of US and EU Implementation of Iran Sanctions Relief

On January 16, 2016, the International Atomic Energy Agency verified that Iran had complied with the nuclear-related technical aspects of the Joint Comprehensive Plan of Action it had to complete before the first phase of...more

FCC Clears Path for U.S. Telecom Companies to Provide Services to Cuba

The Federal Communications Commission recently removed Cuba from its "Exclusion List," allowing telecommunications companies to offer telephone and internet services between the United States and Cuba without separate...more

Obama Administration Further Relaxes Sanctions in Support of Cuba Policy

If you read one thing… - Further relaxation of sanctions on Cuba, effective on January 27, 2016, allows U.S. financial institutions to finance authorized exports and reexports to Cuba of items other than...more

OFAC and BIS Announce Further US Sanctions Authorizations and Export Licensing Policies for Cuba

The US Departments of the Treasury and Commerce are taking further action to implement President Obama's initiatives to normalize US-Cuba relations and to “engage and empower the Cuban people.” The measures announced...more

Sanctions Against Iran Are Lifted

On January 16, 2016, the United States and European nations lifted oil and financial sanctions that have been imposed against Iran since 1979. These actions signal what is being called “Implementation Day” which refers to the...more

Cyber Activities Added to the OFAC Target List – How do you ensure you are compliant?

In December of 2015 the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued regulations implementing the President’s April 1, 2015 Executive Order (“EO”), “Blocking the Property of Certain Persons...more

Implementation Day and the Lifting of Sanctions Against Iran

On January 16, 2016, the International Atomic Energy Agency confirmed that Iran had fulfilled its initial nuclear-related obligations under the Joint Comprehensive Plan of Action (JCPOA) that had been reached in July between...more

Top Compliance Issues Facing Manufacturers in 2016

In the last several years, the U.S. has been aggressively enforcing laws governing exports and international conduct. This is amply illustrated by the continuing imposition of large penalties on multinational companies for...more

Learning from Schlumberger’s Mistakes: Doing Business Under Iran General License H

Lauren Connell, Managing Associate at The Volkov Law Group, rejoins us for a posting on sanctions compliance. Implementation Day has been hailed as a new stage in Iran-US relations. There has been significant media...more

Updated Cuban Assets Control Regulations Will Be Published Tomorrow

The Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced today, January 26, that they are amending the Cuban Assets Control Regulations (“CACR”) to further deliver on improving the United States’...more

Beneficial Ownership: Sanctions and FCPA Compliance

Financial institutions have been pushing back hard on FinCEN’s proposal to require banks, investment banks and other financial institutions to identify beneficial owners of account holders. As time goes on the impact of...more

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