Office of Foreign Assets Control

News & Analysis as of

The Global Magnitsky Human Rights Accountability Act: Sanctions Tool for Promoting U.S. Human Rights Agenda

Overview - After months of closed-door discussions, Congress this week released the text of the negotiated National Defense Reauthorization Act (“NDAA”) for appropriating defense funds in fiscal year 2017. Tucked deep...more

International AML Enforcement in 2017 Expected to Target Consumer-Due-Diligence Programs, Gaming Entities, Prepaid Cards, Digital...

Over the past two years, financial regulatory bodies in the United States and Europe have increasingly emphasized consumer due diligence (“CDD”) by financial institutions as a means to combat money laundering and terrorist...more

White Collar Crime Law Enforcement in a Trump Justice Department - 8 Predictions

After a conventional presidential campaign, determining the policy priorities and direction of the incoming administration with respect to the Justice Department’s white collar law enforcement responsibilities can be a...more

Still Serious About Sanctions: OFAC Settles Violations Involving Cuba and Iran

Lest U.S. companies think that Cuba and Iran are entirely open for business, a U.S. government settlement announced earlier this month with National Oilwell Varco, Inc. (NOV), a U.S. oilfield services company, will serve as a...more

Post-Election Sanctions Hangover

With the results in from the U.S. presidential election, companies should begin to consider the potential impact of a Trump presidency on their international business. U.S. economic sanctions were among the hot-button issues...more

Digital Currency Exchange Customers Targeted in IRS Information-Gathering Sweep

Coinbase, one of the largest digital currency exchange companies in the world, will likely be asked to provide the Internal Revenue Service (IRS) with transactional data and other information on all U.S. customers who used...more

Previewing Trade Policy in the Trump Administration - Part 3: Sanctions

Throughout Donald Trump’s campaign, a prominent theme was the candidate’s willingness to address perceived shortcomings in the United States’ trade policies and dealings with foreign countries. These...more

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

This edition of the Cozen O’Connor Aviation Regulatory Update discusses DOT’s recently issued consumer protection rules and initiatives, the GAO’s report on air traffic control reorganization, DOT’s tentative approval of...more

DOJ Establishes Voluntary Self-Disclosure Program for Criminal Violations of U.S. Economic Sanctions and Export Controls

On October 2, 2016, the National Security Division (NSD) of the U.S. Department of Justice (DOJ) established a formal, voluntary self-disclosure program for criminal violations of U.S. economic sanctions and export controls...more

US Department of Justice Guidance Seeks to Encourage Voluntary Self-Disclosure of Export Controls and Sanctions Violations

The Guidance parallels the DOJ approach under the FCPA, but does not specify the value of mitigation and may create contradictory incentives. The National Security Division (NSD) of the US Department of Justice (DOJ)...more

Sanctions Update: Burma, Cuba, and Iran

Over the past month, substantial changes were made to several sanctions programs affecting Burma, Cuba, and Iran by President Obama and the Department of Treasury Office of Foreign Assets Control (OFAC)....more

Sanctions in Energy: Russia and Iran

US and EU sanctions related to Russia and Iran have a direct and targeted impact on the energy sector. The sanctions regimes against Russia and Iran differ substantially and seem to be moving in different directions. In this...more

[Event] Finance Forum - December 1st, Charlotte, NC

Cadwalader, Wickersham & Taft LLP is sponsoring its inaugural Finance Forum in Charlotte, North Carolina on December 1st.  Join Cadwalader, Wickersham & Taft LLP and fellow industry leaders to discuss emerging trends, market...more

Sanctions Roundup: Third Quarter 2016 and Executive Order on Burmese Sanctions

OFAC, acting under the direction of President Obama’s Executive Orders, has lifted the economic and financial sanctions against Burma and Côte D’Ivoire. The revisions open these countries, and their financial markets, to...more

Investing in Cuban Health Care Biotech Industries

The Obama Administration made significant new regulatory changes to allow certain investment opportunities in the Cuban health care and biotech industries. While many barriers remain, US firms in the health care industry...more

US Sanctions Against Burma Lifted on October 7 With President's Executive Order

On Friday, October 7, 2016, President Obama delivered on a promise that he had made in September by signing an executive order terminating the economic and financial sanctions program on the country of Burma (Myanmar). The...more

Iran on Your Mind? The FAR Should Be, Too.

Over the past year, the big news for companies doing or considering business in Iran has been the scaling back of U.S. and EU economic sanctions. Many global businesses are now permitted to operate in this once prohibited...more

Fraud is Flourishing: Canada’s Regulatory Patchwork Paves Way for Financial Crimes

Fraud is alive and well in Canada. It is thriving and fraudsters are innovating. This boom in white-collar crime is partly the result of Canada’s lack of a uniform regulatory system and ineffective law enforcement....more

New Changes to Federal Regulations Create New Opportunities in Cuba for U.S. Businesses

On October 17, 2016 the U.S. Office of Foreign Assets Control (OFAC) and the U.S. Department of Commerce's Bureau of Industry and Security (BIS) published respective amendments to the Cuban Assets Control Regulations and...more

"OFAC and BIS Implement Additional Amendments in Support of Cuba Policy Shift"

On October 14, 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) announced further amendments to ease U.S. sanctions and...more

DOJ Publishes Guidance Encouraging Voluntary Self-Disclosures, Full Cooperation and Timely and Appropriate Remediation

On Oct. 2, 2016, the U.S. Department of Justice (DOJ), National Security Division (NSD) published Guidance setting forth its policy of encouraging business organizations to voluntarily self-disclose criminal violations of...more

US lifts remaining sanctions on Burma

On October 7, 2016, the US Treasury Department's Office of Foreign Assets Control (OFAC) announced the termination of all remaining financial and trade sanctions against Burma (aka Myanmar). The removal of sanctions followed...more

US Further Liberalizes Cuba Sanctions and Export Controls

On October 14, 2016, the United States announced additional measures to liberalize Cuba sanctions and export controls, effective October 17, 2016. The new measures, which are summarized below, authorize additional...more

US Implements Sixth Round of Eased Cuba Sanctions

On October 17, the US Departments of Commerce and the Treasury announced the sixth round of eased sanctions and export controls designed to bolster trade between the United States and Cuba. The amendments by the Bureau of...more

AGG Food and Drug Newsletter - October 2016

Arnall Golden Gregory LLP's Food and Drug Newsletter is a monthly update of legal and regulatory issues that affect the FDA-regulated community, including regular updates on legislative initiatives from AGG’s Washington, DC...more

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