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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

OFAC Enforcement Trends in the Health Care, Agriculture and Tech Industries

The United States Department of the Treasury's Office of Foreign Assets Control (OFAC), the U.S. governmental agency tasked with administering and enforcing economic sanctions against hostile targets in furtherance of U.S....more

Another Reason To Always Run Compliance Screenings Even If You Are A Non-U.S. Party – OFAC Is Targeting Foreign Companies

If you are a foreign company that wants access to the U.S. financial markets, make sure you understand the U.S. Iran Transactions and Sanctions Regulations (ITSR). Administered by the U.S. Department of Treasury’s Office of...more

Iran and Russia Sanctions Programs Under a Trump Administration–What to Expect

In the final weeks of December, President Obama amended sanctions to both the Iran and Russia programs. These changes further relaxed sanctions on Iran while they tightened sanctions on Russia. Yet, just three days from the...more

Secondary Sanctions Can Prove Tricky for Both U.S. and Non-U.S. Companies - Export Compliance Matters

What are secondary sanctions? Secondary sanctions apply to non-U.S. persons for wholly non-U.S. conduct that occurs entirely outside U.S. jurisdiction. Compare this to primary sanctions, which prohibit U.S. persons from...more

Please Read the Fine Print About Doing Business in Cuba

I am here to encourage newly authorized trade to and from Cuba. However, my job is also to ensure that exporters have all of the information they need to make informed business decisions and remain compliant with U.S. trade...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

Cyber Activities Added to the OFAC Target List – How do you ensure you are compliant?

In December of 2015 the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued regulations implementing the President’s April 1, 2015 Executive Order (“EO”), “Blocking the Property of Certain Persons...more

Is Iran Open for Business for U.S. Exporters?

On August 7, 2015, the U.S. Government issued a revised Guidance regarding Iran and also issued a Third Amended Statement of Licensing Policy on Activities Related to the Safety of Iran’s Civil Aviation Industry. The bottom...more

OFAC Adds 7 Venezuelan Officials to SDN List

On March 8 President Obama signed Executive Order 13692 Executive Order 13692, which initially adds seven former or current Venezuelan government officials to OFAC’s Specially Designated Nationals (SDN) List. Once they have...more

Update: U.S. Ramps Up Ukraine-Related Sanctions Yet Again

On December 19th, President Obama signed Executive Order (EO) 13685 specifically targeting Crimea and those responsible for the usurpation of the peninsula back in March. This latest EO was the forth in a series aimed at...more

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

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

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