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
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
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
On December 26, 2012 the Department of the Treasury's Office of Foreign Assets Control ("OFAC") published a final rule amending the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (the "ITSR"), to implement...more
On December 11, a major international bank holding company announced agreements with U.S. law enforcement authorities and federal bank regulators to end investigations into alleged inadequate compliance with anti-money...more
HSBC Holdings, London, and two of its U.S. subsidiaries have been ordered to pay a record $1.92 billion in fines and penalties for anti-money laundering (AML) and Office of Foreign Assets Control (OFAC) violations....more
On November 16, 2012, the Obama Administration announced that the U.S. would begin to allow imports from Burma (Myanmar), ending a decade-old ban on Burmese imports. The decision, published in a joint announcement by the U.S....more
President Obama issued an Executive Order on Oct. 9, 2012, implementing recent legislation barring foreign subsidiaries of U.S. companies from engaging in most transactions with Iran and making the U.S. parent companies...more
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