On 9 November 2017, the Trump Administration implemented new regulations to support its change to U.S. policy on Cuba. The U.S. Government has created a new Cuba Restricted List administered by the State Department. Through...more
On 27 October, the U.S. Department of State published guidance with respect to Russia’s Defense and Intelligence sectors under section 231 of the Countering America’s Adversaries The Sanctions Act (CAATSA). Section 231...more
Yesterday, on October 12, 2017, the U.S. permanently revoked most sanctions against Sudan. This lifting represents the completion of a process that began in January 2017, and was extended in July 2017. ...more
10/13/2017
/ Agricultural Sector ,
Banking Sector ,
Charitable Organizations ,
Commerce Control List ,
Economic Sanctions ,
Export Controls ,
Medical Devices ,
Office of Foreign Assets Control (OFAC) ,
Pharmaceutical Industry ,
SDN List ,
State Sponsors of Terrorism ,
Sudan ,
Universities
Press reports indicate that President Trump intends to “de-certify” the Iran nuclear deal this week. In practical terms, that means he would refuse to re-certify one or more statutory elements of a law passed by the U.S....more
On Sunday, Sept. 24, 2017, President Trump signed a presidential proclamation (the Proclamation) laying out restrictions on the entry of nationals from eight countries into the United States using certain types of immigrant...more
10/2/2017
/ B-1 ,
B-2 ,
Department of Homeland Security (DHS) ,
Executive Orders ,
Foreign Nationals ,
Foreign Workers ,
Green Cards ,
Immigrants ,
Immigration Procedures ,
Immigration Reform ,
National Security ,
Refugees ,
Terrorist Threats ,
Travel Ban ,
Trump Administration ,
Visas
Effective August 25, 2017, President Trump issued a new Executive Order, (the Order), which targets the Government of Venezuela’s (GOV) and Petroleos de Venezuela, S.A.’s (PdVSA) ability to access capital from the United...more
One day after the Venezuelan government held elections for a Constituent Assembly that the United States has asserted is aimed at rewriting the national constitution, the Department of the Treasury’s Office of Foreign Assets...more
On Tuesday, July 25, the U.S. House of Representatives passed H.R. 3364, the Countering America’s Adversaries Through Sanctions Act by a vote of 419-3.
There is some uncertainty, but the legislation is expected to be...more
On 8 August 2017, the European Union Financial Sanctions (Amendment of Information Provisions) Regulations 2017 (the "Regulations") will come into force. The Regulations "expand the scope of the reporting requirements set out...more
Ahead of a Constituent Assembly that could re-write the Venezuelan Constitution and dissolve state institutions, the U.S. Treasury Department’s Office of Foreign Assets Control has designated 13 current and former Venezuelan...more
On July 17, the Department of State communicated to Congress that Iran remains in compliance with its obligations under the Joint Comprehensive Plan of Action (JCPOA), the nuclear agreement reached over Iran’s nuclear program...more
Last week, the U.S. Senate acted to pass both new Iran and Russia sanctions by large bipartisan margins. The House of Representatives has not yet acted on either piece of legislation. We anticipate that Congress will...more
6/21/2017
/ Cybersecurity ,
Human Rights ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Mining ,
Nuclear Weapons ,
Pending Legislation ,
Railways ,
Russia ,
Shipping ,
Terrorist Threats
On Friday, 16 June 2017, President Trump made his first major foray into U.S. - Cuban relations since assuming office. While it was a radical departure in tone from his predecessor, the changes he announced appear to leave...more
On May 18, 2017, U.S. Trade Representative (USTR) Robert Lighthizer formally notified Congress of the Trump Administration's intent to renegotiate the North American Free Trade Agreement (NAFTA) with Mexico and Canada. The...more
5/26/2017
/ Canada ,
Countervailing Duties ,
Cross-Border Transactions ,
Exports ,
Free Trade Agreements ,
Imports ,
Mexico ,
NAFTA ,
Trade Relations ,
Trans-Pacific Partnership ,
Trump Administration ,
USTR
While much attention has been focused on the Trump Administration's recent actions targeting imports of metals, lumber, and other commodities, the Administration has also steadily ramped up its activities in the trade...more
5/1/2017
/ Chemical Weapons ,
Executive Orders ,
Exports ,
Exxon Mobil ,
Imports ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
National Security ,
Offshore Drilling ,
Oil & Gas ,
Russia ,
Syria ,
Trump Administration ,
U.S. Treasury
On April 3, 2017, the Council of the European Union approved a new regulation intended to prevent the trade in conflict minerals, which followed the approval of the European Parliament on March 16, 2017. This puts an end to...more
On 6 March 2017, President Donald Trump signed a new Executive Order (EO), "Protecting the Nation From Foreign Terrorist Entry Into the United States." The new EO revokes Executive Order 13769 from 27 January 2017 and imposes...more
3/6/2017
/ Customs and Border Protection ,
Department of Homeland Security (DHS) ,
Executive Orders ,
Foreign Nationals ,
Green Cards ,
Immigrants ,
Immigration Procedures ,
Immigration Reform ,
National Security ,
Refugees ,
Terrorist Threats ,
Travel Ban ,
Trump Administration ,
Visa Interview Waiver Program (VIWP) ,
Visas
On Friday, February 3, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) announced it was designating 25 entities and individuals as Specially Designated Nationals (SDNs) for their involvement in...more
2/14/2017
/ Foreign Policy ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
National Security ,
Nuclear Weapons ,
Office of Foreign Assets Control (OFAC) ,
Procurement Guidelines ,
SDN List ,
Terrorist Threats ,
Trump Administration ,
U.S. Treasury ,
WMD
On February 9, 2017 the U.S. Court of Appeals for the Ninth Circuit issued a unanimous (per curiam) order denying the Federal Government's emergency motion for a stay of the district court order temporarily enjoining...more
2/13/2017
/ Department of Homeland Security (DHS) ,
Dual Citizenship ,
Executive Orders ,
Foreign Nationals ,
Green Cards ,
Immigrants ,
Immigration Procedures ,
Immigration Reform ,
Iran ,
Iraq ,
Libya ,
Refugees ,
Somalia ,
Sudan ,
Syria ,
Terrorist Threats ,
Travel Ban ,
TRO ,
Trump Administration ,
Visas ,
Yemen
Earlier this month, the Securities and Exchange Commission (SEC) announced its Office of Compliance Inspections and Examinations’ (OCIE) 2017 Examination Priorities regarding certain practices, products, and services that...more
1/31/2017
/ AML/CFT ,
Anti-Money Laundering ,
Broker-Dealer ,
BSA/AML ,
Cybersecurity ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Institutions ,
Financial Markets ,
OCIE ,
Personally Identifiable Information ,
Popular ,
SEC Examination Priorities ,
Securities and Exchange Commission (SEC) ,
Terrorism Funding
On Friday, January 27, 2017, President Trump signed an executive order temporarily barring the entry of refugees and citizens from certain countries into the United States. The order, "Protecting the Nation from Foreign...more
1/31/2017
/ Department of Homeland Security (DHS) ,
Dual Citizenship ,
Executive Orders ,
Foreign Nationals ,
Green Cards ,
Immigrants ,
Immigration Procedures ,
Immigration Reform ,
Iran ,
Iraq ,
Libya ,
Somalia ,
Sudan ,
Syria ,
Travel Ban ,
Trump Administration ,
Visas ,
Yemen
On December 23, 2016, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) published a number of changes to the Iranian Transactions and Sanctions Regulations (“ITSR,” 31 C.F.R. Part 560) that expanded the...more
1/20/2017
/ Agricultural Sector ,
Commodities ,
Export Controls ,
Exports ,
General Licenses ,
Healthcare ,
Imports ,
Iran ,
Iran Sanctions ,
Manufacturers ,
Medical Devices ,
Obama Administration ,
Office of Foreign Assets Control (OFAC) ,
Pharmaceutical Industry ,
Software
On January 13, 2017, the White House, the U.S. Department of Treasury ’s Office of Foreign Assets Control (OFAC) , and the U.S. Department of Commerce ’s Bureau of Industry and Security (BIS) announced a host of policy...more
1/18/2017
/ Africa ,
Aircraft ,
Aircraft Equipment ,
Aircraft Sales ,
Aviation Industry ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Executive Orders ,
Export Controls ,
Exports ,
Financial Institutions ,
Food Supply ,
Insurance Industry ,
Medical Devices ,
Obama Administration ,
Pharmaceutical Industry ,
Prescription Drugs ,
Reinsurance ,
Sudan ,
Transportation Industry
The New York Department of Financial Services (NYDFS) just issued major revisions to the cybersecurity regulations for financial institutions that were due to come into effect on January 1, 2017. To allow covered institutions...more
1/3/2017
/ Banking Sector ,
Chief Information Security Officer (CISO) ,
Cybersecurity ,
Cybersecurity Framework ,
Data Protection ,
Encryption ,
Financial Institutions ,
Financial Services Industry ,
Insurance Industry ,
NYDFS ,
Popular ,
Risk Assessment ,
Risk Management