Office of Foreign Assets Control

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AGG Food and Drug Newsletter - September 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

“Reason To Know” – A Chilling Term For Exporters

It’s a simple question – if a U.S. exporter sells its product to a foreign customer, and the customer resells the product to a prohibited country such as Iran, can the U.S. exporter have liability for an export violation? ...more

President Obama Pledges to Lift Myanmar Sanctions

On September 14, 2016, President Obama met with Myanmar’s leader, State Counsellor Daw Aung Suu Kyi, at the White House and announced the United States’ intent to remove economic sanctions against Myanmar (formerly known as...more

Burma Sanctions Regulations to be Terminated

On September 14, 2016, the President announced his intention to terminate the national emergency with respect to Burma, the effect of which will be to end the current U.S. sanctions program against that country as overseen by...more

Every U.S. Life Sciences Company Needs an Export Control Compliance Program (No, Really….)

Two recent settlements by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) confirm that every U.S. life sciences company engaging in exports should have an effective U.S. export control compliance...more

OFAC Expands List of Persons Subject to Sanctions Under Ukraine-/Russia-Related Sanctions Authorities

On September 1, 2016, the Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury (Treasury) designated 37 new individuals and entities as Specially Designated Nationals and Blocked Persons (SDNs)...more

Russia Sanctions Update: OFAC, BIS Expand Sanctions Lists

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued new Russia/Ukraine-related sanctions on Thursday, September 1, 2016. This action marks OFAC’s first major expansion of the Specially...more

Extension of Russia / Ukraine Related Sanctions - Sanctioned Entity - Glavgosekspertiza - Russian federal institution for official...

On 1 September 2016, the US Department of the Treasury's Office of Foreign Assets Control (OFAC) supplemented sanctions against Russia imposed in connection with the conflict in Eastern Ukraine with names of a number of...more

US Designates Additional Russian and Ukrainian Individuals and Entities, Issues New General License

On September 1, 2016, the US Department of the Treasury's Office of Foreign Assets Control (OFAC) added 37 Russian and Ukrainian individuals and entities to the List of Specially Designated Nationals and Blocked Persons (SDN...more

Considerations for Travel to Iran to Explore Relaxed Trade Opportunities

Before booking your airfare, be mindful of these potential issues. In light of liberalized trade with Iran made possible by the Office of Foreign Assets Control’s (OFAC’s) General License H and the relaxation of US...more

OFAC General License Loosens Restrictions on Non-US Carrier Flights to Iran

On Friday, July 29, the US Office of Foreign Assets Control (OFAC) issued General License J under the Iranian Transactions and Sanctions Regulations (ITSR). This general license authorizes non-US airlines to fly US origin...more

Changes in Cuba May Impact the Insurance Industry

While much remains to be determined, the recent easing of U.S. restrictions on travel to and trade with Cuba may bring opportunities for U.S. and global insurance companies. However, many questions and obstacles remain. This...more

Anti-Corruption, Sanctions and Export and Import Risks

Forgive me for overusing the term “convergence” but when the shoe fits, I say “wear it.” If you are managing corporate risks and responsible for securing export licenses, ensuring that you are complying with OFAC sanctions...more

IRS Publishes List of Countries Requiring Cooperation with an International Boycott

Non-listed countries can also present compliance issues under both IRS and Commerce Department Requirements. On August 5, the US Department of the Treasury’s Internal Revenue Service (IRS) published in the Federal...more

Layover in Tehran: United States Authorizes Carriers to Land Civil Aircraft in Iran

On July 29, 2016, the U.S. Treasury Office of Foreign Assets Control (OFAC) cleared the runway for non-U.S. operators of civil aircraft to send flights into Iran. New “General License J” authorizes many Boeing, Airbus, and...more

AML Update: The NYDFS’s New Anti-Money Laundering Regulation and its Annual Compliance Certification Requirement

This summer, one of the nation’s top state regulators for finance announced a major new AML regulation, providing a critical hook for regulatory liability for companies that lack effective anti-money laundering controls. An...more

From Altamont to Airbus

What was one of the most tragic events in the history of rock and roll? High up on the list must rank the Altamont concert, held at Altamont Race Track on December 6, 1969. It was so bad that many people felt the 60s actually...more

Insurers Beware: The Risks of Failing to Comply With OFAC SDN Screening Requirements

Two related enforcement actions by the U.S. Department of Treasury’s Office of Foreign Assets Compliance (OFAC) are stark reminders that health insurance providers (and other insurers) must maintain adequate U.S. trade...more

August 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 new FAA reauthorization legislation, DOT awards for U.S. carrier scheduled service to Cuba, DOT’s decision to address consumer notification requirements...more

New License Authorizing U.S. Aircraft to Make Temporary Sojourns to Iran Marks Further Lifting of Secondary Sanctions

Further weakening secondary sanctions, the Department of Treasury’s Office of Foreign Assets Control has issued a new license to allow non-U.S. persons to fly some U.S. aircraft to Iran for temporary sojourn. While General...more

OFAC Cites Violations in Dealings with Specially Designated Nationals

Insurance companies and financial institutions are targeted. On August 2, the US Department of the Treasury's Office of Foreign Assets Control (OFAC) issued a Finding of Violation against two different insurance...more

OFAC Issues Findings of Violations of the Foreign Narcotics Kingpin Sanctions Regulations against a Health Insurer and Third Party...

On August 2, 2016, the Office of Foreign Assets Control (“OFAC”) issued Findings of Violations of the Foreign Narcotics Kingpin Sanctions Regulations against AXA Equitable Life Insurance Company and Humana Inc. In both cases,...more

Cleared for Takeoff: OFAC’s General License J Allows Boeing, Airbus and Other Aircraft to Land in Iran

On July 29, 2016, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) issued a new General License J (GL-J). GL-J authorizes the reexportation of certain civil aircraft on temporary sojourn to Iran,...more

OFAC’s New Civil Monetary Penalties Catch Up with Inflation

Effective August 1, 2016, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) will amend its regulations to raise the statutory maximum civil monetary penalty that can be assessed for a violation of...more

Six Months After Implementation of Iran Nuclear Agreement: Top 10 Observations

Various factors continue to shape and limit trade and investment between Iran and the rest of the world. Six months have passed since the implementation of the nuclear agreement with Iran, officially known as the Joint...more

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