Effective July 1, 2013, President Obama's Executive Order 13645 implements certain provisions of the Iran Freedom and Counter-Proliferation Act of 20121 (IFCA) and expands the Iranian sanctions regime to new sectors of Iran’s...more
Introduction - US sanctions restrictions have traditionally exempted exchanges of information and informational materials. However, because the prohibitions on exports of software and services are sufficiently broad to...more
Most significantly, on June 3, 2013, President Obama issued Executive Order 13645 (78 Fed. Reg. 33945) that, effective July 1, 2013, implements provisions of the Iran Freedom and Counter-Proliferation Act of 2012 and imposes...more
On May 30, 2013, the Office of Foreign Assets Control (“OFAC”) of the United States Department of the Treasury announced the issuance of a general license authorizing the exportation to Iran of certain services, software, and...more
President Obama has issued a new Executive Order that goes into effect July 1, 2013. The Executive Order targets new areas of the Iranian economy for sanctions, including exchange transactions involving Iranian Rials and...more
Introduction - The Myanmar Ministry of Energy (Ministry) has commenced an auction for 30 oil and gas blocks in the Myanmar offshore areas. The auction invites bids for 11 shallow water blocks and 19 deep water blocks,...more
In this issue: - OFAC Releases New SDN Search Tool - Additional Provisions Targeting Iran Go Into Effect - OFAC Continues to Target Foreign Sanctions Evaders - Section 219 Disclosures Begin - Burma...more
On April 4, the Federal Reserve Board released a March 25, 2013 written agreement between the Federal Reserve Board, the New York Department of Financial Services, and a German bank and its U.S. branch regarding certain...more
Originally published in BNA’s Banking Report, 100 BBR 617 on 04/02/2013. Overall Trends & Outlook - In 2012, the federal banking agencies, including the Federal Deposit Insurance Corporation (‘‘FDIC’’), Office...more
Foreign nationals with an interest in expanding their businesses in America often find themselves trying to navigate a complicated regulatory scheme from applying for visas to understanding U.S. laws. With clients in Europe...more
Recent improvements in the political environment of Burma have allowed for some easing of sanctions, with the ultimate goal of increasing U.S. trade with Burma. Most recently, on February 22, 2013, the Department of...more
Effective February 6, 2013, companies required to file quarterly and annual reports (10Qs and 10Ks) with the Securities and Exchange Commission (SEC) are required to include information about certain of their own and their...more
On February 6, 2013, the Office of Foreign Assets Control (OFAC) published two guidance documents related to the Iranian sanctions regulations and licenses. The first is Guidance on Humanitarian Assistance and Related...more
The United States Court of Appeals for the Second Circuit issued an opinion on February 14, 2013, holding that the civil liability provision of the Anti-Terrorism Act of 1990, 18 U.S.C.§ 2333(a) (the “ATA”) does not permit...more
The Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury enforces comprehensive sanctions that regulate, and largely forbid, most forms of trade and financial transactions by U.S. persons with Iran....more
As the new year brings in a new term for the Obama Administration, the pace of Iran sanctions shows no sign of slowing. As we reported in October and November, Washington’s commitment to denying Iran the ability to advance...more
A number of companies have filed IRANNOTICEs on EDGAR with the SEC (thanks to Broc Romanek for pointing this out). The notices reference disclosures made in annual reports pursuant to Section 219 of the Iran Threat Reduction...more
Recently, Standard Chartered Bank (SCB) was in the news again for stripping original wire details so that payments would go undetected by the U.S. Department of Treasury's Office of Foreign Assets Control (OFAC)....more
As 2013 begins, the United States has reiterated its commitment to countering the threat posed by Iran by passing new legislation, issuing new regulations and guidance, and bringing into effect new requirements to increase...more
Mandatory requirements cover actions of issuers' foreign subsidiaries and affiliates. On August 10, 2012, section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012 (the Act), 112 P.L. 158, added new...more
On January 10, the Office of Foreign Assets Control (OFAC) issued an advisory to highlight practices being used to evade sanctions on Iran, including the use of third-country exchange houses or trading companies that are...more
In This Issue: - FEDERAL ISSUES - STATE ISSUES - COURTS - FIRM NEWS - FIRM PUBLICATIONS - MORTGAGES - BANKING - CONSUMER FINANCE - E-COMMERCE - PRIVACY/DATA SECURITY - PAYMENTS -...more
The United States continues to impose additional layers of sanctions on Iran. The rate of change and complexity of U.S. sanctions laws present challenges, particularly where these sanctions have extraterritorial effect on the...more
On August 10, 2012, the United States delivered its latest economic blow to Iran by enacting the Iran Threat Reduction and Syria Human Rights Act of 2012. U.S. companies have long been forbidden from engaging in most...more
Grace period through March 8 provided to foreign subsidiaries to wind down Iranian transactions. On December 26, 2012, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) amended the Iranian...more
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