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News & Analysis as of

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

Africa Update - January 2016 #4

Leading the News - Burundi - On January 22nd, during a visit to Bujumbura, the United Nations (U.N.) Security Council met with Burundian President Pierre Nkurunziza to advocate for peace talks and the deployment of...more

Iran Sanctions Implementation Day: Engaging in Business in Iran through Foreign Subsidiaries?

On January 16, 2016, various iterations of "Iran Sanctions Lifted" appeared in the headlines. Taking this quote literally, the assumption is that the doors are now open to freely engage in business with Iran. A closer look,...more

The Visa Waiver Program – Know Before You Go

Almost everyone who enters the U.S. for business visits must either (a) have a B-1 visa (which may include a B1/B2 visa) or (b) be eligible to enter without a visa under the Visa Waiver Program. If you have a...more

Changes to the Visa Waiver Program

In the aftermath of the Paris and San Bernardino attacks, the Visa Waiver Program (VWP) was amended significantly on December 18, 2015, when the enactment of the 2016 Consolidated Appropriations Act (H.R. 2029) was signed...more

New Limitations on Visa-Less Travel to the U.S.

The U.S. Department of Homeland Security (DHS) and the Department of State on Jan. 21, 2016, commenced implementation of changes to the Visa Waiver Program (VWP) pursuant to the Visa Waiver Program Improvement and Terrorist...more

Changes to Visa Waiver Program Take Effect

The US Department of State (DOS) has begun implementing changes under the Visa Waiver Program Improvement and Terrorist Travel Prevention Act of 2015. Signed into law on December 18, 2015, the Act establishes new criteria for...more

DOS and DHS Announce Changes to the Visa Waiver Program

The Department of State and Department of Homeland Security issued a joint statement on January 21, 2016 on the implementation of certain changes under the Visa Waiver Program Improvement and Terrorist Travel Prevention Act...more

ESTA Travel Warning Update – Approval Revoked for Travelers who are Nationals of Iran, Iraq, Syria or Sudan

The Department of State announced that travelers who currently have valid Electronic System for Travel Authorizations (ESTAs) and who have previously indicated holding dual nationality with Iran, Iraq, Sudan or Syria on their...more

Learning from Schlumberger’s Mistakes: Doing Business Under Iran General License H

Lauren Connell, Managing Associate at The Volkov Law Group, rejoins us for a posting on sanctions compliance. Implementation Day has been hailed as a new stage in Iran-US relations. There has been significant media...more

United States Implements New Visa Waiver Program Restrictions

The Department of Homeland Security (“DHS”) and Department of State (“DOS”) announced immediate implementation of the Visa Waiver Program Improvement and Terrorist Travel Prevention Act of 2015. Under the Act, certain...more

U.S. Department of State Implements Visa Waiver Program Entry Restrictions

The budget bill, which was signed into law in December, disallows “Visa Waiver” entries for nationals of Iran, Iraq, Syria or Sudan (whether or not they have ever visited those countries) and persons from any country who have...more

Visa Waiver Program Changes Now Being Implemented

VWP nationals who have visited Iran, Iraq, Sudan, or Syria since March 1, 2011, or who hold dual nationality with one of the countries are no longer eligible for the VWP....more

Africa Update - January 2016 #2

Leading the News - Burundi - On January 12th, the Burundian Justice Ministry indicated the verdict on the trial of former Defense Minister Cyrille Ndayirukiye and 27 others accused of plotting the failed coup...more

New Restrictions for Travelers Entering the USA on the Visa Waiver Program

The Visa Waiver Program (VWP) allows citizens of qualifying countries to travel to the United States for business or pleasure without a visa for stays of up to 90 days. The 2016 Consolidated Appropriations Act (H.R. 2029)...more

Africa Update - December 2015 #3

Leading the News - Libya: On December 11th, the new United Nations (U.N.) Special Representative for Libya Martin Kobler announced the parties to the country’s political dialogue process reached an agreement to...more

Africa Update - December 2015

Leading the News - Nigeria: On December 1st, the United Nations (U.N.) reported nearly 450 schools have reopened in Borno state, Nigeria since October after being closed for more than 18 months following the Boko...more

Africa Update - November 2015 #3

Leading the News - Egypt: On November 12th, officials at the U.S. National Transportation Safety Board (NTSB) and the Federal Bureau of Investigation (FBI) noted while they had offered assistance to both Egyptian...more

Africa Update - November 2015

Leading the News - Egypt: On October 31st, a Russian jet carrying 217 passengers and seven crew members crashed in Egypt’s Sinai Peninsula, killing all people on board. While the cause of the crash was not...more

Africa Update - October 2015 #4

Leading the News - Tanzania: On October 25th, voters in Tanzania went to the polls to vote for a candidate to replace outgoing President Jakaya Kikwete, who was unable to run for a third term under the country’s...more

Africa Update - October 2015 #3

On October 17th, members of the United Nations (U.N.) Security Council urged all Libyan parties to endorse and sign the recently finalized political agreement for the creation of a Government of National Accord. The Security...more

Africa Update - October 2015 #2

Leading the News - Libya: On October 8th, The Washington Post provided an update on the Islamic State of Iraq and the Levant’s (ISIL) activities in Sirte, Libya. Since taking hold of Sirte earlier this year, ISIL...more

What Exactly Is “Constructive Engagement”?

Yesterday, I wrote about SB 185 (De León) which mandates that California’s two giant pension funds to liquidate their investments in thermal coal companies on or before July 1, 2017.  One aspect of the bill that I didn’t...more

Africa Update - October 2015

Leading the News - Burkina Faso: On October 1st, authorities in Burkina Faso said General Gilbert Diendere, the leader behind a recent coup attempt in the country, was in the custody of security forces. According to...more

Africa Update - September 2015 #5

Leading the News - Burkina Faso: On September 25th, the United Nations (U.N.) Security Council issued a statement welcoming the reinstatement of President Michel Kafando and the transitional authorities of Burkina...more

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