News & Analysis as of

United States Changes Policy on Cuba

As widely reported, President Obama announced on December 17, 2014, significant changes to U.S. policy relating to Cuba. The broad policy revisions include the following...more

Obama’s Reboot of U.S.-Cuba Relations: What Does It Mean?

Last Wednesday, President Obama announced the most sweeping changes to U.S.-Cuban relations in half a century, in effect beginning normalization to a relationship fractured by the pressures of the Cold War. Only baby steps...more

US Issues Executive Order Prohibiting Crimea-Related Transactions and General License No. 4 Authorizing Humanitarian Exports to...

On December 19, 2014, President Obama signed an Executive Order (EO) prohibiting a broad range of transactions related to the Crimea region of Ukraine and authorizing the United States to impose sanctions on certain persons...more

Trade Sanctions Roundup: U.S. Closes Out 2014 with Major Actions on Cuba, Russia, and Syria

The end of 2014 has seen major developments in U.S. foreign relations and sanctions policy with broad implications for the maritime industry. On December 17, President Obama announced a paradigm shift in relations with Cuba,...more

New Law Significantly Expands Legal Basis for US Sanctions Against Russia

On 16 December 2014, President Obama announced that he will sign the Ukraine Freedom Support Act of 2014 (hereinafter the “Act”) into law. As discussed in our update dated 12 December 2014, the Act represents a potentially...more

US Clarifies Sanctions Provisions and US Senate Passes a Bill to Codify and Expand Sanctions

As noted in previous updates, the United States and European Union continue to impose sanctions against Ukrainian and Russian individuals and entities as a result of the turmoil in Ukraine. On 11 December 2014, the US Senate...more

OFAC Settles with Independent Manufacturer for Alleged Violations of the Cuban Assets Control Regulations

Recently, OFAC settled with a Portland, Oregon based manufacturer for allegedly violating the Cuban Assets Control Regulations, 31 C.F.R. part 515. The manufacturer agreed to pay $2,057,540 for the actions of its subsidiary,...more

OFAC Sanctions Compliance Provisions in Agreements

Due to costly settlements secured by U.S. regulatory agencies, banks, insurers, and corporations are increasingly inserting rigorous OFAC sanctions compliance language into their credit agreements, insurance policies, and...more

Red Notice Newsletter - November 2014

Welcome to the November 2014 edition of Red Notice, a publication of Akin Gump Strauss Hauer & Feld LLP. This month on the anticorruption front, a life sciences company settles multi-country bribery investigations, a...more

Managing Legal and Business Risks Under the Russia/Ukraine Sanctions

On October 9, 2014 a team of US, Russia and UK based Latham & Watkins lawyers hosted “Managing Legal and Business Risks Under the Russia/Ukraine Sanctions: Views from the US, Europe and Moscow,” a webcast focusing on the...more

Sanctions Relating to Russia Imposed by the U.S., EU, Australia and Japan - A Snapshot of Where We Are Now

Since early March 2014, a number of countries have imposed various types of sanctions against Russia and certain persons in Ukraine in connection with events in Ukraine. We have issued a series of updates covering, in...more

Test Your Knowledge on OFAC Sanctions

Global sanctions have shot up the scale of high risks to be prioritized by international companies and financial institutions, including real estate, corporate and trust service provider businesses. The battle against...more

OFAC Issues New General License Excepting Turkish Lender from Russian Sanctions

On October 6, 2014, the Treasury Department’s Office of Foreign Assets Control (OFAC) issued General License No. 3, excepting DenizBank AS, a Turkish lender, from the restrictions on access to new debt or new equity under...more

Recent Trends in DOJ Investigations Against Major Financial Institutions Involving U.S. Economic Sanctions

With the imposition of billion-dollar fines against large financial institutions, the U.S. Department of Justice ("DOJ") is focusing on banks for not only failing to comply with federal laws, but also for willfully violating...more

Overview of the U.S. and EU Sanctions on Russia

Over the past six months, the United States and the European Union have coordinated efforts through sanctions and trade controls to respond to Russian activity in Crimea and Ukraine. Following a long series of incremental...more

Complicating Sanctions Compliance: OFAC Redefines 50 Percent Rule

Companies are worried more and more about sanctions compliance. As the number and complexity of sanctions grow, depending on the twists and turns of our foreign policy, companies are whipsawed in the area of sanctions...more

U.S. Steps Up Sanctions and Export Controls Against Russia’s Defense Industry

The United States recently expanded sanctions and export controls against the Russian defense sector. These designations and export control steps have implications for defense contractors, parts suppliers and brokers....more

17 Red Flags for Potential International-Sanctions Violations

Recent events in Ukraine and the Middle East have expanded sanctions placed by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) against certain foreign financial institutions and individuals. This...more

Update on U.S. Sanctions Relating to Ukraine

U.S. Sanctions - On September 12, the United States, in coordination with the EU, imposed additional sanctions against Russia in connection with events in Ukraine. Specifically... - the Office of Foreign Assets...more

New US sanctions on Russia’s financial, defense and energy sectors impact US companies

The US Department of Treasury’s Office of Foreign Assets Control (OFAC) has issued additional sanctions targeting certain Russian banks, energy and defense companies. The sanctions, issued September 12, 2014, are intended to...more

New U.S. Restrictions on Russia: OFAC Guidance and Industry-Specific Sanctions

OFAC Expands the 50 Percent Rule - Last month, the Department of Treasury’s Office of Foreign Assets Control (OFAC) released new guidance related to entities owned or controlled by persons designated as a Specially...more

Bank Settles With OFAC Regarding Civil Action for Apparent Violation of Sudanese Sanctions Regulations

The Office of Foreign Assets Control (“OFAC”) posted a summary of a settlement with a bank (the “Bank”) relating to a transaction that OFAC alleged was processed by the Bank in violation of OFAC’s Sudanese Sanctions...more

OFAC Makes Important Update to Ownership/Control Guidance

On August 13, 2014, the Office of Foreign Assets Control (OFAC) issued new guidance on ownership/control for determining blocked parties. This represented the first significant update on this topic since February 14, 2008,...more

OFAC Issues Revised Guidance on Entities Owned by Persons Whose Property and Interests in Property are Blocked

The Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has issued revised guidance with respect to entities owned 50 percent or more in the aggregate by one or more blocked persons....more

OFAC Issues New Guidance Regarding Status of Entities Owned by Specially Designated Nationals and Blocked Persons

The U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued new guidance regarding the status of entities that are 50% or more owned by persons or entities whose property and interests in property are...more

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