News & Analysis as of

US Implements Additional Measures to Liberalize Cuba Sanctions

On September 21, 2015, the United States further amended existing regulations to implement the changes announced by President Obama on December 17, 2014 liberalizing US sanctions and export controls targeting Cuba. As a...more

Shrinking Sanctions: New Changes Allow U.S. Companies to Establish Cuban Business Presence

Policy changes announced by the Obama administration on September 18 will allow U.S. food and agriculture companies, U.S. telecommunications companies and U.S. building material supplier companies to establish a business...more

US revises Cuba sanctions regulations to further normalize trade with Cuba

On September 18, 2015, the US Department of Treasury and US Department of Commerce released significant revisions to the US embargo on Cuba, as set out in the Cuban Assets Control Regulations (CACR) and the Export...more

US Government Further Relaxes Trade Restrictions with Cuba

However, the new transaction rules leave the embargo largely in effect. Early this week, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Department of Commerce’s Bureau of Industry and...more

Obama Administration Further Eases Restrictions to Aid Implementation of Cuba Policy

On Monday, September 21, 2015, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) implemented amendments to the Cuban...more

Cheap Flights for Flying Blind

European discount airline Germanwings has a practice it calls “Blind Booking”. The concept is straightforward. Essentially you don’t know your destination city until after you have booked the flight. But for €33...more

3 Keys to Child Safety

Although summer has come to a close, lots of families continue to hit the roads (and even the seas and air) on vacation over long weekends, holidays and school vacations. Most divorced families agree upon a parenting plan...more

Advertising Requirements in PERM—A Survey of BALCA’s Application of 20 CFR § 656.17(f)(7)

The U.S. Department of Labor’s (DOL) permanent labor certification (PERM) program requires employers to conduct specific recruiting activities to test the labor market before filing an application. The regulation at 20 CFR §...more

Rate Parity Under Attack

Over the last decade, Online Travel Agents (“OTAs”), such as Expedia, Travelocity, and, have gained enormous market power. The OTAs have advertising budgets that dwarf those of most hotels, and they benefit from...more

FCC Issues $2.96 Million Fine for Robocalling Violations

Last week, the FCC issued its self-described “largest forfeiture order” to date for robocalling violations. The Commission announced the $2.96 million fine against a travel company based in Tampa, Florida, and its owner, for...more

OTAs and the Back-Tax Parade

On Wednesday, August 13, 2015, the Montana Supreme Court issued a ruling in Department of Revenue v. Priceline, holding that online travel agencies (“OTAs”)—including Priceline, Expedia, Travelocity, Orbitz, and...more

Traveling to the United States: Restricting the Visa Waiver Program While Expanding the Trusted Traveler Programs

The Department of Homeland Security continues in its attempts to balance security considerations and hospitality to foreign visitors. The fascinating dilemma it confronts can be highlighted by press releases issued on...more

9th Circuit Holds No Coverage for DVT Under Employee Death Benefit Policy

In Williams v. National Union Fire Insurance Company of Pittsburgh, PA, 2015 U.S. App. LEXIS 11642 (9th Cir. July 7, 2015), the Ninth Circuit Court of Appeals, applying California law, had the opportunity to consider whether...more

Tracking the Flight of the Snowbird

It is the time of year when the seasons change…And snowbirds return to Canada from their winter havens…And I debunk the common myths about the immigration rules for visitors. For many of us non-snowbirds who weathered...more

Bridging the Gap to Cuba

Last December, President Barack Obama announced a series of changes to the United States’ policy toward Cuba. The most significant changes, from a foreign policy perspective, included restoring diplomatic relations with Cuba...more

Trusted Traveler Programs: Expanded Resources for Today’s Business Traveler

Companies of all sizes have increased workforce mobility needs arising from international short-term relocations, business visits, trade shows, conferences, speaking engagements, etc. It is critical for today’s business...more

Shifting Course: Expanding the Scope of Permissible Cuba Transactions

The Treasury Department’s Office of Foreign Assets Control (“OFAC”) has issued its first set of amendments to the Cuban Assets Control Regulations (“CACR”) to begin implementing a major policy shift in United States–Cuba...more

Havana Hold Your Hand: Reaching Out to Cuban Entrepreneurs

New regulations on Cuba enter into force today, only 29 days after President Obama promised them. The liberalized provisions focus on support for private sector actors in Cuba. As we described here, the President announced on...more

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

U.S. Embargo Against Cuba: Historic Changes Ahead

On December 17, 2014, President Barack Obama announced sweeping changes in the diplomatic and trade relationships between the United States and Cuba. These changes, outlined below, will require time to implement; certain...more

President Obama’s Announcement on U.S.-Cuban Relations Could Create Strategic Opportunities for American Companies

On December 17, 2014, the United States announced its intention to normalize diplomatic relations with Cuba. President Obama stated that, after nearly 54 years of economic and political isolation, his administration will be...more

New Channels of Economic Opportunity to Follow U.S.-Cuba Policy Changes

On December 17, President Obama announced sweeping changes to U.S.–Cuba policies that will usher in a new era in bilateral relations between the two countries. In the coming months, the United States will move to re-establish...more

SEC Files Settled FCPA Action Centered On Improper Travel

A “world tour” was at the center of FCPA violations by two employees of FLIR Systems, Inc., In the Matter of Stephen Timms, Adm. Proc. File No. 3-16281 (Nov. 17, 2014). Travel was also the focus of the Commission’s latest...more

Global HR Hot Topic—December 2014: Overseas Business Travel Liability and the Duty of Care in Times of Ebola

As of late 2014, the United States faced no Ebola pandemic whatsoever. The odds of catching Ebola in an American workplace remained statistically zero. Only a handful of Ebola cases had made their way to the United States,...more

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