Office of Foreign Assets Control

News & Analysis as of

UPDATE re Is New York's Proposal a Harbinger of Things to Come? Certification of BSA/AML Compliance and Personal Liability for...

Update - This announcement comes just days after New York Governor Andrew Cuomo nominated Maria Vullo, another lawyer, to replace Benjamin Lawsky, who resigned as the Superintendent of the Department of Financial...more

FinCrimes Update - January 2016 Summary, Volume 4, Issue 1

JANUARY FINCRIMES WEBINAR RECAP: 2015 ENFORCEMENT ACTIONS: LESSONS LEARNED FOR REGIONAL AND SUPER-REGIONAL BANKS - On January 28, 2016, BuckleySandler hosted 2015 Enforcement Actions: Lessons Learned for Regional and...more

Despite the Fanfare, Iranian Sanctions Remain Largely in Place

To read many of the media reports, the United States has withdrawn sanctions on Iran and Iran is now open for business. Contrary to such reports, the United States sanctions on Iran remain substantially unchanged. ...more

Overview of US and EU “Implementation Day” Guidelines on Iran Sanctions Relief

This overview describes the status of US and EU sanctions following the first round of nuclear-related sanctions relief that occurred on “Implementation Day” under the Joint Comprehensive Plan of Action (JCPOA) concluded with...more

Business Opportunities in Iran for US Automotive Manufacturers through non-US Subsidiaries

Implementation Day for the Iranian JCPOA - January 16, 2016 marked Implementation Day for the Joint Comprehensive Plan of Action (JCPOA), as the US Secretary of State confirmed that the International Atomic Energy Agency...more

OFAC Fines Foreign Bank For Violating 50 Percent Rule

The U.S. Department of Treasury's Office of Foreign Assets Control ("OFAC") continued Monday, February 8, 2016, to direct the weight of its enforcement power at foreign banks, this time entering into a $2,485,890 settlement...more

Treasury and Commerce further relax US Cuba sanctions

On January 26, 2016, the Obama Administration released its third update to the US Cuba sanctions in the past two years. To effectuate these changes, the US Treasury Department’s Office of Foreign Assets Control (OFAC) further...more

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

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