News & Analysis as of

Office of Foreign Assets Control

Trump Administration Re-Certifies Iranian Compliance with Nuclear Agreement; Imposes Sanctions on Additional Entities for Other...

by Hogan Lovells on

On July 17, the Department of State communicated to Congress that Iran remains in compliance with its obligations under the Joint Comprehensive Plan of Action (JCPOA), the nuclear agreement reached over Iran’s nuclear program...more

Trump Administration Extends Sudan Sanctions Review Period by Three Months

On January 13, 2017, President Obama issued Executive Order 13761 to be effective on July 12, 2017, which would revoke prior executive orders underlying the Sudanese Sanctions Regulations and effectively terminate the Sudan...more

U.S. Government Delays Decision on Sudan Sanctions

On July 11, 2017, the President issued an Executive Order (E.O.) extending the review period for the possible permanent revocation of sanctions on Sudan for an additional three months. On January 13, 2017, then-President...more

Trump Tightens Cuba Sanctions

by King & Spalding on

On June 16, 2017 President Trump announced new policy parameters for the U.S.-Cuba relationship and directed the Office of Foreign Assets Control (OFAC), Department of Treasury, Bureau of Industry and Security (BIS),...more

Lessons in Civil Forfeiture and Attachment: U.S. May Seize 650 Fifth Avenue

by Ballard Spahr LLP on

On June 29, dual trial verdicts in the Southern District of New York paved the way for the government to seize 650 Fifth Avenue, a 36-story building in Manhattan valued at up to $1 billion (“the Property”). The defendants,...more

Sanctions Round Up: First Half

by Shearman & Sterling LLP on

The first six months of the Trump Administration saw several notable developments for US sanctions, with particular implications for Russia and Iran. The Administration also declared a shift in US policy toward Cuba. ...more

Red Notice Newsletter - June 2017

ANTICORRUPTION DEVELOPMENTS - Linde Group Receives DOJ Declination Pursuant to FCPA Pilot Program - On June 16, 2017, German based chemical and gas company Linde Group’s American affiliates, Linde North America Inc....more

FCRA Violations Lead to Record-Breaking $60 Million Verdict

On June 19, a jury sitting in federal court in the United States District Court for the Northern District of California awarded plaintiffs $60 million after finding that the defendant, TransUnion, LLC, violated provisions of...more

Trans Union Hit with Largest FCRA Verdict to Date

Trans Union, LLC, one of the largest credit reporting agencies in the United States has been hit with a verdict by a California jury for $60 million, which is the largest verdict under the Fair Credit Reporting Act (FCRA) to...more

TransUnion Hit with Record $60 Million Dollar Verdict in FCRA Class Action

by Hinshaw & Culbertson LLP on

A California jury recently returned a large verdict in a Fair Credit Reporting Act ("FCRA") case which alleged that TransUnion's credit reporting confused the class consumer names with the names of criminals and terrorists on...more

President Trump Revises U.S. Policy on Cuba

by Jones Day on

On June 16, 2017, President Trump announced revisions to U.S. policy toward engagement with Cuba and a limited rollback of certain sanctions relief provided by the Obama Administration....more

California Ruling Requires TransUnion to Pay Record $60M for FCRA Violations; Suit Alleged Consumer Reports Erroneously Linked...

by Kelley Drye & Warren LLP on

A California jury in federal court ruled on Tuesday, June 20, that TransUnion violated the Fair Credit Reporting Act (FCRA) by erroneously linking certain consumers with similarly named terrorists and criminals in the U.S....more

Rare Court Case Sheds Light on U.S. Sanctions Enforcement

by Bass, Berry & Sims PLC on

It is rare for companies to go to court to fight penalties imposed by the Office of Foreign Assets Control (OFAC) for violations of U.S. sanctions. It is even more rare for a court to make any sort of finding against the...more

Trump changes Cuba policy

by Taylor English Duma LLP on

On June 16, 2017, President Trump announced that he was reversing several Obama-era policies regarding Cuba. Against the backdrop of a Miami museum that celebrates the unsuccessful Bay of Pigs invasion, Trump’s announcement...more

Cuba & Trump: What the Changes Mean

by Latham & Watkins LLP on

On December 17, 2014, President Obama announced that the United States would “chart a new course” on its Cuba policy. Starting in January 2015, and for the next two years, the Treasury Department’s Office of Foreign Assets...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

United States Announces New Cuba Policy

by White & Case LLP on

On June 16, 2017, President Trump issued the "National Security Presidential Memorandum on Strengthening the Policy of the United States Toward Cuba" (the "Cuba Memorandum") describing the Administration’s policy on Cuba and...more

Treasury Department Issues FAQ on Impact of Cuba Policy Shift

by Baker Donelson on

On June 16, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) issued a press release answering 12 "Frequently Asked Questions" ahead of President Trump's announcement of a revised U.S. policy...more

Obama to Trump: Before and After on Cuba

by Hogan Lovells on

On Friday, 16 June 2017, President Trump made his first major foray into U.S. - Cuban relations since assuming office. While it was a radical departure in tone from his predecessor, the changes he announced appear to leave...more

US announces new Cuba sanctions policy, changing the landscape in key sectors

by Dentons on

On June 16, 2017, US President Donald Trump unveiled his much-anticipated Cuba sanctions policy in what was billed as a major speech in Miami, Florida. While implementing regulations have yet to be published, the president's...more

President Trump Announces New Cuba Restrictions

by WilmerHale on

On June 16, 2017, President Trump announced new sanctions restrictions under the US embargo against Cuba. Although US policy since 2014 has been to normalize US-Cuba relations and liberalize trade with Cuba, President Trump...more

President Trump Announces Changes to Cuba Policy

by Cozen O'Connor on

On June 16, 2017, President Trump announced changes to the U.S. policy toward Cuba aimed at tightening travel restrictions on U.S. persons and limiting the Cuban military’s access to U.S. dollars. Although announced on June...more

Cuba Sanctions: President Trump Announces Tightening of U.S. Sanctions While Maintaining Certain Sanctions Relief Implemented by...

On June 16, 2017, the Trump administration issued a national security presidential memorandum entitled “Strengthening the Policy of the United States Towards Cuba” (the “Presidential Memorandum”). Related to this...more

President Trump’s Cuba Policy Changes Have Limited Practical Impact – For Now

by Dechert LLP on

President Trump announced just before the weekend that he will reinstate certain travel and commercial restrictions related to Cuba that had been eased under the Obama Administration. While President Trump declared that he...more

OFAC Enforcement Trends in the Health Care, Agriculture and Tech Industries

by Baker Donelson on

The United States Department of the Treasury's Office of Foreign Assets Control (OFAC), the U.S. governmental agency tasked with administering and enforcing economic sanctions against hostile targets in furtherance of U.S....more

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Cybersecurity

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