On August 5, 2019, President Donald Trump signed Executive Order 13884, Executive Order Blocking Property of the Government of Venezuela (EO 13884). EO 13884 is designed to further increase pressure on the Nicolás Maduro...more
8/7/2019
/ Blocked Person ,
Citgo ,
Economic Sanctions ,
Executive Orders ,
Financial Institutions ,
Foreign Policy ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Petroleum ,
Trump Administration ,
U.S. Treasury ,
Venezuela
Bank Secrecy Act/anti-money laundering (BSA/AML) and sanctions matters continue to be a core focus of regulators, law enforcement agencies, policymakers and Congress, and the story of the Obama and Trump Administrations on...more
7/29/2019
/ Anti-Money Laundering ,
BSA/AML ,
Cuba ,
Customer Due Diligence (CDD) ,
Drug Trafficking ,
Economic Sanctions ,
Enforcement Actions ,
FinCEN ,
Human Trafficking ,
Iran ,
Magnitsky Act ,
Nicaragua ,
North Korea ,
Russia ,
Sudan ,
Trump Administration ,
Venezuela ,
Virtual Currency
On May 15, 2019, President Trump issued an Executive Order (EO) declaring a national emergency and paving the way for a ban on the use of Huawei equipment and services in U.S. telecommunication networks. On the same day, the...more
5/17/2019
/ Bureau of Industry and Security (BIS) ,
China ,
Executive Orders ,
Exports ,
General Licenses ,
Imports ,
National Security ,
Savings Clause ,
Supply Chain ,
Telecommunications ,
Trade Relations ,
Trump Administration ,
U.S. Commerce Department ,
US Trade Policies
On March 27, 2019, the Office of Foreign Assets Control (OFAC) announced a settlement agreement with US-based Stanley Black & Decker, Inc., (Stanley Black & Decker) and its foreign subsidiary, Jiangsu Guoqiang Tools Co., Ltd....more
4/2/2019
/ Black & Decker ,
Chief Compliance Officers ,
Compliance ,
Corporate Counsel ,
Economic Sanctions ,
Enforcement Actions ,
Exports ,
Foreign Subsidiaries ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
Settlement ,
Subsidiaries
Yesterday, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated Petróleos de Venezuela, S.A. (PdVSA) pursuant to Executive Order 13850, adding the state-owned Venezuelan oil company to its...more
On November 28, the Treasury Department sanctioned two Iran-based individuals for exchanging bitcoin into Iranian rials on behalf of malicious cyber actors involved in the SamSam ransomware scheme. Notably, this action marks...more
12/3/2018
/ Bitcoin ,
Crypto Exchanges ,
Cryptocurrency ,
Digital Currency ,
Economic Sanctions ,
Iran ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
Ransomware ,
SDN List ,
U.S. Treasury
On November 5, 2018, the United States took steps to complete the U.S. withdrawal from the Joint Comprehensive Plan of Action (“JCPOA”), under which the United States – along with its partners in the P5+1 – had previously...more
11/9/2018
/ Blocked Entities ,
Economic Sanctions ,
EU ,
Executive Orders ,
Financial Institutions ,
General Licenses ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
P5+1 Nations ,
SDN List ,
Trump Administration ,
UN Security Council
On August 1, 2018, the US Department of Commerce Bureau of Industry and Security (BIS) published a Federal Register notice stating that the US government had identified 44 Chinese companies as acting contrary to US national...more
On Friday, May 18, the EU Commission launched the formal process to reactivate a 1996 trade defense law in response to the US withdrawal from the Joint Comprehensive Plan of Action (JCPOA) on Iran's nuclear program. Once...more
5/23/2018
/ Blocking Statutes ,
China ,
EU ,
European Commission ,
Foreign Relations ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Russia ,
Trade Relations ,
Trump Administration
On Tuesday, May 8, President Trump announced that the United States would end its participation in the Joint Comprehensive Plan of Action (JCPOA), signed by the Permanent Five Members of the Security Council plus Germany...more
President Trump has issued new Proclamations regarding Section 232 tariffs on steel and aluminum, amending the original Proclamations (9704 and 9705) issued on March 8. The most notable changes concern country-wide...more
This morning, the U.S. Department of Commerce Bureau of Industry and Security (BIS) issued an interim final rule establishing the process by which organizations may submit requests for exclusions from the 25% duties on steel...more
Yesterday President Trump signed two Proclamations that impose 25 and 10 percent tariffs on imports of certain steel and aluminum products, respectively, other than those imported from Canada and Mexico. The imposition of...more
President Trump stated on March 1 that his administration would impose a 25 percent tariff on steel imports and a 10 percent tariff on aluminum imports for an indefinite period. This was a preview of formal determinations...more
On December 20, 2017, President Trump issued a new Executive Order (EO) targeting corruption and human rights abuses around the world.
The EO implements last year's Global Magnitsky Human Rights Accountability Act (the...more
On November 9, 2017, the US Departments of the Treasury and Commerce implemented President Trump's June 2017 National Security Presidential Memorandum (NSPM) that was designed to tighten restrictions on individual travel to...more
Over the past several years, as North Korea has increased the capability of its nuclear and ballistic missile program, there has been a steady increase in sanctions pressure against North Korea by the United States and the...more
On August 24, 2017, the Trump Administration significantly expanded sanctions against the Government of Venezuela, including state-owned oil company Petroleos de Venezuela, S.A. (PdVSA). These latest sanctions reflect...more
On July 27, the US Senate passed the Countering America's Adversaries Through Sanctions Act (CAATSA), a comprehensive sanctions bill that expands US sanctions against three countries: Russia, Iran, and North Korea. The...more
On June 16, 2017, President Trump announced new sanctions restrictions under the US embargo against Cuba. Although US policy since 2014 has been to normalize US-Cuba relations and liberalize trade with Cuba, President Trump...more
As North Korea continues its provocative missile tests and nuclear activities, the United States appears poised to adopt secondary sanctions that would target Chinese and other firms conducting business with Pyongyang. Global...more
Over the past year, regulators continued to actively examine compliance, introduce new and heightened requirements, recalibrate global priorities, and aggressively pursue enforcement. This report reviews recent trends and...more
4/28/2017
/ BSA/AML ,
Cuba ,
Economic Sanctions ,
Enforcement Actions ,
FATF ,
Financial Services Committee ,
FinCEN ,
Iran ,
NYDFS ,
Russia ,
Securities and Exchange Commission (SEC)
On April 18, 2017, the State Department certified to Congress that Iran was in compliance with its obligations under the Joint Comprehensive Plan of Action (JCPOA) between the United States, Iran, and the P5+1 nations. It...more
Do physicians ‘‘condition participation’’ of drug therapy based on patients’ compliance with drug manufacturer instructions regarding how to take drugs? Do physicians withhold medically necessary drug therapy from patients...more
New Iran Designations -
On Friday, the US Treasury Department's Office of Foreign Assets Control (OFAC) designated 25 individuals and entities under Executive Orders 13382 and 13224 for their roles in procuring...more