OFAC

Myanmar - New round of auctions for offshore oil and gas blocks: Baker & McKenzie

by John Mollard, David Ryan, Melinda Tun | Baker & McKenzie Australia on 5/9/2013

Introduction - The Myanmar Ministry of Energy (Ministry) has commenced an auction for 30 oil and gas blocks in the Myanmar offshore areas. The auction invites bids for 11 shallow water blocks and 19 deep water blocks,...more

Federal Reserve Board, New York DFS Issue Joint Enforcement Action Against U.S. Branch Of Foreign Bank

by BuckleySandler LLP on 4/12/2013

On April 4, the Federal Reserve Board released a March 25, 2013 written agreement between the Federal Reserve Board, the New York Department of Financial Services, and a German bank and its U.S. branch regarding certain...more

2012 Bank Enforcement Actions Still High, But Significantly Lower Than 2010-11

by Robert H. Ledig, Robert Rhatigan, Aline Smith, Thomas P. Vartanian | Dechert LLP on 4/4/2013

Originally published in BNA’s Banking Report, 100 BBR 617 on 04/02/2013. Overall Trends & Outlook - In 2012, the federal banking agencies, including the Federal Deposit Insurance Corporation (‘‘FDIC’’), Office...more

Coming To America? Six Considerations For Foreign Entrepreneurs

by The R. Bernard Law Group on 4/1/2013

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

Burma – Trade is looking up by way of General Licenses, but caveats still remain.

by Doreen Edelman | Baker, Donelson, Bearman, Caldwell &... on 3/6/2013

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

10Qs and 10Ks Now Required to Include Transactions Subject to Economic Sanctions

by Baker, Donelson, Bearman, Caldwell &... on 2/28/2013

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

Alert: Clarifications of the Iranian Sanctions Regulations

by Sheppard Mullin Richter & Hampton LLP on 2/21/2013

On February 6, 2013, the Office of Foreign Assets Control (OFAC) published two guidance documents related to the Iranian sanctions regulations and licenses. The first is Guidance on Humanitarian Assistance and Related...more

The United States Court of Appeals for the Second Circuit Rejects Aiding and Abetting Liability for Civil Damage Claims Under the...

by Linda Goldstein | Dechert LLP on 2/20/2013

The United States Court of Appeals for the Second Circuit issued an opinion on February 14, 2013, holding that the civil liability provision of the Anti-Terrorism Act of 1990, 18 U.S.C.§ 2333(a) (the “ATA”) does not permit...more

New Iran Sanctions Enactments Apply to U.S. Companies’ Foreign Affiliates and Subsidiaries, and Require SEC Reporting by Public...

by Burt Braverman, Jennifer Frewer | Davis Wright Tremaine LLP on 2/20/2013

The Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury enforces comprehensive sanctions that regulate, and largely forbid, most forms of trade and financial transactions by U.S. persons with Iran....more

New Law Expands Scope of Iran Sanctions In New Ways

by Scott Maberry, Matthew Riemer | Sheppard Mullin Richter & Hampton LLP on 2/15/2013

As the new year brings in a new term for the Obama Administration, the pace of Iran sanctions shows no sign of slowing. As we reported in October and November, Washington’s commitment to denying Iran the ability to advance...more

IRANNOTICEs Begin To Roll Into The SEC

by Stephen M. Quinlivan | Leonard, Street and Deinard - Dodd-Frank and... on 2/13/2013

A number of companies have filed IRANNOTICEs on EDGAR with the SEC (thanks to Broc Romanek for pointing this out). The notices reference disclosures made in annual reports pursuant to Section 219 of the Iran Threat Reduction...more

Wire Stripping: What is Old is New Again

by Joseph D. Gustavus, Jeffrey Richardson | Miller Canfield on 1/29/2013

Recently, Standard Chartered Bank (SCB) was in the news again for stripping original wire details so that payments would go undetected by the U.S. Department of Treasury's Office of Foreign Assets Control (OFAC)....more

The New Year Brings New Sanctions Against Iran

by King & Spalding on 1/25/2013

As 2013 begins, the United States has reiterated its commitment to countering the threat posed by Iran by passing new legislation, issuing new regulations and guidance, and bringing into effect new requirements to increase...more

SEC Reporting for Certain 2012 Iran-Related Transactions

by Margaret Gatti, Linda Griggs, Timothy Rolland, Louis Rothberg | Morgan Lewis on 1/23/2013

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

OFAC Issues Advisory On Efforts To Evade Iran Sanctions

by BuckleySandler LLP on 1/22/2013

On January 10, the Office of Foreign Assets Control (OFAC) issued an advisory to highlight practices being used to evade sanctions on Iran, including the use of third-country exchange houses or trading companies that are...more

Infobytes - A Weekly In-depth review of news & developments in the financial services industry - January 18, 2013

by BuckleySandler LLP on 1/22/2013

In This Issue: - FEDERAL ISSUES - STATE ISSUES - COURTS - FIRM NEWS - FIRM PUBLICATIONS - MORTGAGES - BANKING - CONSUMER FINANCE - E-COMMERCE - PRIVACY/DATA SECURITY - PAYMENTS -...more

Iran Sanctions Update

by Jonathan M. Epstein | Holland & Knight LLP on 1/16/2013

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 Reporting Requirements Under the Iran Threat Reduction and Syria Human Rights Act of 2012

by Benji Jones, A. Heath Tripp | Smith, Anderson, Blount, Dorsett, Mitchell &... on 1/15/2013

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

New OFAC Regulations Implement Iranian Sanctions

by Margaret Gatti, Timothy Rolland, Louis Rothberg | Morgan Lewis on 1/9/2013

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 Mark J. Biros, Benjamin R. Ogletree, Michael P. Richter | Proskauer Rose LLP on 12/31/2012

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

U.S. Law Enforcement Authorities And Regulators Resolve Significant Money Laundering And Sanctions Investigations

by BuckleySandler LLP on 12/21/2012

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

Record Fines against HSBC for Repeated Bank Secrecy Act and OFAC Violations

by John Dodge | Davis Wright Tremaine LLP on 12/17/2012

Following on the heels of the $15 million settlement against First Bank of Delaware for significant Bank Secrecy Act/Anti-Money Laundering violations (as we reported on here), the Treasury Department and three federal...more

Record $1.92 Billion in Fines and Penalties Levied against HSBC

by Keith R. Fisher, Alan S. Kaplinsky, Beth Moskow-Schnoll | Ballard Spahr LLP on 12/14/2012

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

U.S. Eases Burma (Myanmar) Import Ban

by J. Garrett Cornelison | BakerHostetler on 11/28/2012

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

Iran Sanctions: U.S. Bans Foreign Subsidiaries of U.S. Companies from Doing Business with Iran

by Jonathan M. Epstein | Holland & Knight LLP on 10/11/2012

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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