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New Sanctions Imposed For Human Rights Abuses and Corruption – a Harbinger For Business in 2018?

On December 21, the U.S. Treasury Department announced the implementation of a new global sanctions regime under the Magnitsky Human Rights Accountability Act (the “Global Magnitsky Act”). President Trump issued an Executive...more

Iran Sanctions Update: No Change for Companies as Pressure Shifts Back to President Trump as Key Deadline Passes

On December 12, a key deadline passed for Congress to reimpose nuclear-related sanctions against Tehran, shifting the pressure back to the executive branch and setting new deadlines that will be critical to the fate of the...more

Best Practices for Compliance with North Korea OFAC Sanctions

As we discussed further at length, the U.S. and nations around the world have recently sought to implement and impose harsh economic sanctions programs against North Korea to pressure Pyongyang into ceasing its development...more

Cuba Sanctions Guidance: November 2017 Update

On November 9, 2017, changes to the United States' Cuba Sanctions program went into effect, as the Department of Treasury's Office of Foreign Assets Control (OFAC) and the Department of Commerce's Bureau of Industry and...more

Cuba Policy Shift Stalls as Businesses Await OFAC Implementation

On June 16, 2017, President Trump issued a National Security Presidential Memorandum on Strengthening the Policy of the United States Toward Cuba. The Memorandum outlined a framework for agencies such as the Treasury...more

Sudan Sanctions Revocation Formalized, But Compliance Challenges Remain

On October 12, 2017, the Treasury Department’s Office of Foreign Assets Control (OFAC) revoked certain parts of its economic sanctions regime with respect to Sudan and the Government of Sudan. OFAC issued a General License...more

Iran Speech Shifts Pressure to Congress, But Changes Little for U.S. Businesses

President Trump’s October 13 speech denounced Iran’s “fanatical regime” as a “menace,” and threatened to terminate the 2015 Iran nuclear deal negotiated by Barack Obama and formally known as the Joint Comprehensive Plan of...more

Your Foreign Business Partners Must Choose – Do Business with the U.S. or North Korea

On Thursday September 21st, President Trump signed Executive Order 13810 Imposing Additional Sanctions with Respect to North Korea (” the E.O.” or “E.O. 13810”). E.O. 13810 significantly expands the U.S. Treasury...more

New Sanctions Law: Congress Seeks to Limit President Trump’s Ability to Modify U.S. Policy Toward Russia

On August 2nd, President Trump signed into law the “Countering America’s Adversaries Through Sanctions Act” (H.R. 3364), which gives the President the power to solely waive or terminate sanctions against Russia if Congress...more

OFAC Imposing Penalties on Non-U.S. Companies

A recent OFAC enforcement case illustrates that even non-U.S. companies that do business with sanctioned jurisdictions under the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) face significant risks...more

8/7/2017  /  Economic Sanctions , Exports , OFAC

Treasury Department Issues FAQ on Impact of Cuba Policy Shift

On June 16, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) issued a press release answering 12 "Frequently Asked Questions" ahead of President Trump's announcement of a revised U.S. policy...more

Update on Regulatory Compliance in the Global Health Care Industry

A comprehensive understanding of the constantly evolving layers that make up federal anti-corruption statutes, sanctions regulations and export control restrictions is imperative for both the pharmaceutical and health care...more

Tips To Avoid Inadvertent Violations of OFAC’s Sanctions Against Russia

A year ago I posted an overview of OFAC’s Ukraine and Russia-related sanctions program. Although the Executive Orders and program structure described in that post have not been changed or expanded, it is important to remember...more

2/19/2016  /  Crimea , Economic Sanctions , OFAC , Russia , SDN List
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