News & Analysis as of

Subsidiaries Office of Foreign Assets Control

OFAC Fines American Honda for Foreign Subsidiary’s Business with Cuba

by Baker Donelson on

American Honda Finance Corporation (American Honda) has settled with the Office of Foreign Assets Control (OFAC) over potential civil liability for 13 violations of the Cuban Assets Control Regulations (CACR), which that...more

Secondary Sanctions Can Prove Tricky for Both U.S. and Non-U.S. Companies - Export Compliance Matters

by Baker Donelson on

What are secondary sanctions? Secondary sanctions apply to non-U.S. persons for wholly non-U.S. conduct that occurs entirely outside U.S. jurisdiction. Compare this to primary sanctions, which prohibit U.S. persons from...more

SEC Reporting for Certain 2012 Iran-Related Transactions

by Morgan Lewis on

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

Iran Sanctions Update

by Holland & Knight LLP on

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

New OFAC Regulations Implement Iranian Sanctions

by Morgan Lewis on

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

Final Rule on New Iranian Sanctions Published

by Proskauer Rose LLP on

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

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Cybersecurity

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