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DOJ Establishes Voluntary Self-Disclosure Program for Criminal Violations of U.S. Economic Sanctions and Export Controls

On October 2, 2016, the National Security Division (NSD) of the U.S. Department of Justice (DOJ) established a formal, voluntary self-disclosure program for criminal violations of U.S. economic sanctions and export controls...more

New Round of Cuba Sanctions Changes Expand Opportunities for Health Sector

Key Points - - OFAC’s latest changes expand opportunities for U.S. persons to engage in medical research with Cuban nationals, authorize U.S. persons to obtain FDA approval of Cuba-origin pharmaceuticals, and market...more

OFAC Guidance on U.S. Dollar Transactions Involving Iran

On October 7, 2016, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) published new guidance clarifying (a) circumstances under which non-U.S. financial institutions (FFIs) may engage in U.S. dollar...more

Is Chinese Investment in the U.S. Film and Entertainment Industry the Next Area of CFIUS Scrutiny?

U.S. lawmakers recently submitted a letter to the Government Accountability Office (GAO) raising concerns about increased Chinese investments in the U.S. film and entertainment industry and questioning whether the Committee...more

Russia Sanctions Update: OFAC, BIS Expand Sanctions Lists

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued new Russia/Ukraine-related sanctions on Thursday, September 1, 2016. This action marks OFAC’s first major expansion of the Specially...more

Export Control Reform Offers Revisions to Key Terms, and DDTC Increases Penalty Authority; More Work Remains (Part 1)

On June 3, 2016, the U.S. Department of State, Directorate of Defense Trade Controls (DDTC) and the Department of Commerce, Bureau of Industry and Security (BIS) issued changes to the International Traffic in Arms Regulations...more

Waked Money Laundering Organization Sanctions: OFAC Issues General Licenses and Updates

On May 5, 2016, the U.S. Department of Treasury, Office of Foreign Assets Control (OFAC) announced sanctions against 77 entities and individuals associated with the Waked Money Laundering Organization (“Waked MLO,”...more

Tackling a Panamanian Money Laundering Organization: OFAC Sanctions the Waked Money Laundering Organization, Colombia Arrests the...

OFAC Sanctions - On May 5, 2016, the U.S. Department of Treasury, Office of Foreign Assets Control (OFAC) announced sanctions against 77 entities and individuals associated with the Waked Money Laundering Organization...more

DOJ Civil Rights Division Underscores Risk of Discrimination Claims When Requesting Information from Applicants and Employees for...

On March 31, 2016, the Department of Justice’s Civil Rights Division (“DOJ”) issued a technical assistance letter (TAL) that highlights the potential for employers to create discrimination claims inadvertently when requesting...more

OFAC Adopts New Sanctions Targeting Hizballah’s Financial and Logistics Networks

If you only read one thing... - The Hizballah Financial Sanctions Regulations (HFSR) are intended to disrupt Hizballah’s global logistics and financial network by providing a new basis of secondary sanctions...more

OFAC Authorizes Certain Commercial Passenger Aircraft Transactions with Iran

On March 24, 2016, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued General License I authorizing U.S. persons to undertake certain transactions ordinarily incident to the negotiation of, and...more

BIS Grants Temporary Relief for Two ZTE Companies and their Suppliers

In an extraordinary development, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a new rule, effective March 24, 2016, creating a temporary general license for two entities—Zhongxing...more

Obama Administration Further Eases Sanctions in Advance of Cuba Visit

On Wednesday, March 16, 2016, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) implemented amendments to the Cuban...more

U.S. Export Controls Restrictions Imposed on Chinese Telecommunications Giant ZTE

Effective March 8, 2016, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a final rule adding Zhongxing Telecommunications Equipment Corporation (ZTE) of Shenzhen, China, and the following...more

Obama Administration Further Relaxes Sanctions in Support of Cuba Policy

If you read one thing… - Further relaxation of sanctions on Cuba, effective on January 27, 2016, allows U.S. financial institutions to finance authorized exports and reexports to Cuba of items other than...more

What Implementation of the Iran Nuclear Deal Means for Non-U.S. Companies

On January 16, 2016, the International Atomic Energy Agency (IAEA) verified, and U.S. Secretary of State John Kerry confirmed, that Iran had implemented its key nuclear-related measures described in the Joint Comprehensive...more

Sanctions Relief to Expect from the Nuclear Deal with Iran

On July 14, 2015, Iran and the P5+1 countries (China, France, Germany, Russia, the United Kingdom and the United States), with the High Representative of the European Union for Foreign Affairs and Security Policy, finalized...more

OFAC Issues Venezuela Sanctions Regulations

On July 10, 2015, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published, in abbreviated form, Venezuela Sanctions Regulations (VSR) in 31 C.F.R. Part 591. The VSR implement the Venezuela...more

Pushing Deadline for Iran Nuclear Deal, Negotiators Extend Temporary Sanctions Relief for Seven Days

As nuclear negotiations in Vienna reach the targeted June 30, 2015, deadline for an agreement, the P5+1, EU and Iran agreed today to extend the limited and temporary sanctions relief to Iran through July 7, 2015. The...more

OFAC Issues Guidance Regarding the Parameters of Authorized Travel Between the U.S. and Cuba

On May 5, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued guidance regarding travel between the United States and Cuba. In particular, the guidance clarifies that companies authorized to...more

FinCEN Seeks to Curb Trade-Based Money Laundering Through Lowered Reporting Threshold

On April 21, 2015, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued a Geographic Targeting Order (“GTO”) lowering reporting thresholds and triggering additional recordkeeping requirements...more

President to Remove Cuba’s Terrorism Designation: Most Sanctions Remain in Effect

On April 14, President Obama notified Congress of his intent to rescind Cuba’s designation as a State Sponsor of Terrorism (SSOT), issued in March 1982, saying the Cuban government “has not provided any support for...more

Negotiators Agree on Iran Deal Framework Providing Basis for Limited Easing of Sanctions

Thursday, negotiators from the United States, Iran and other world powers announced they have agreed on a framework for a Joint Comprehensive Plan of Action regarding Iran’s nuclear program to be finalized by June 30, 2015....more

Obama Signs Executive Order Establishing Cybersecurity Sanctions Regime

On April 1, 2015, President Obama signed an executive order establishing a new sanctions program targeting individuals and entities responsible for, or complicit in, cyber-enabled activities that threaten the national...more

U.S. Implements Targeted Sanctions on Venezuela

On March 9, 2015, following failed diplomatic efforts to bring Venezuela in line with its human rights commitments under international law, President Obama issued an Executive Order (E.O.) declaring Venezuela a national...more

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