On July 22, 2024, the Department of Treasury, Office of Foreign Assets Control (OFAC) announced a significant planned extension to its recordkeeping requirements, which will increase the retention period from five to ten...more
Last year, we published an update on BIS’s foray into prohibiting EAR99 items for export to Russia and Belarus. We noted (somewhat in jest) that kitchen sinks may one day be added. Well, that day has come. Stainless steel...more
6/21/2024
/ Belarus ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
Software ,
Technology Sector
Effective April 24, the statute of limitations (“SoL”) under the International Emergency Economic Powers Act (“IEEPA”) and the Trading with the Enemy Act (“TWEA”) has been extended from five to ten years. It would have been...more
In response to Russia’s ongoing aggression in Ukraine, both the United States and the European Union have imposed additional sanctions and further restricted exports to Russia and Iran. These new controls span many...more
2/28/2023
/ Economic Sanctions ,
Entity List ,
EU ,
Export Controls ,
Exports ,
Iran ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Trade Restrictions ,
UK ,
Ukraine
In response to Russia’s illegal declaration of annexations of Ukrainian territory, the United States and the European Union have imposed additional sanctions on Russia. U.S. Response On October 4, 2022, the U.S. government...more
After Mahsa Amini was killed in the custody of “Gasht-e-Ershad” or Iran’s Guidance Patrol, commonly referred to as Iran’s morality police, following an arrest for placement of her hijab, protests have erupted throughout Iran...more
Updated as of February 25, 2022 -
Key Takeaways of OFAC (Treasury) and BIS (Commerce) Actions -
Major Russian Banks Blocked from the U.S. Financial System. Six major Russian banks — VEB, Promsvyazbank (PSB), VTB Bank,...more
On January 10, 2017, Senate Republicans and Democrats introduced bi-partisan legislation called the “Countering Russian Hostilities Act of 2017,” which would impose broad sanctions on Russia. The Act would codify the...more
1/13/2017
/ Amended Legislation ,
Barack Obama ,
Bipartisan Agreement ,
Cyber Attacks ,
Cyber Sanctions ,
Economic Sanctions ,
Energy Sector ,
Executive Orders ,
Financial Institutions ,
Foreign Policy ,
Legislative Agendas ,
Office of Foreign Assets Control (OFAC) ,
Pending Legislation ,
Presidential Elections ,
Russia ,
Trump Administration ,
Vladimir Putin
- A President Trump will have authority to reinstate sanctions lifted by the Iran Nuclear Deal as well as revoke certain authorizations provided for business with Iran.
- Several economic and geopolitical factors may...more
12/8/2016
/ Business Opportunities ,
Corporate Counsel ,
Executive Orders ,
Global Market ,
International Relations ,
International Treaties ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Nuclear Weapons ,
Office of Foreign Assets Control (OFAC) ,
Presidential Elections ,
SDN List ,
Trump Administration
With fewer than 100 days left in office, President Obama is not slowing down on his efforts to normalize relations between the United States and Cuba. Today, several changes to the Cuban Assets Control Regulations (CACR) and...more
10/18/2016
/ Aviation Industry ,
Barack Obama ,
Cuba ,
Cuban Assets Control Regulations (CACR) ,
Energy Sector ,
Export Administration Regulations (EAR) ,
Exports ,
Imports ,
Medical Research ,
Office of Foreign Assets Control (OFAC) ,
Travel
The U.S. Treasury Department has signaled the latest focus of its enforcement: real estate ventures with ties to money laundering schemes. Individual real estate investors and companies involved in luxury real estate, real...more
With more flights, relaxing regulations, a historic presidential trip to Cuba, and news of hospitality services expanding into Cuba, the pathway into Cuba for hotels and hospitality companies seems smooth. But businesses...more
After weeks of negotiations and a Putin-backed delay, the UN Security Council unanimously adopted resolution 2270 on March 2, 2016, imposing new sanctions against North Korea. According to U.S. Secretary of State John Kerry,...more
3/4/2016
/ Arms Embargo ,
Asset Freeze ,
Corporate Counsel ,
Exports ,
Imports ,
North Korea ,
Nuclear Weapons ,
Office of Foreign Assets Control (OFAC) ,
Sanctions ,
SDN List ,
UN Security Council ,
Vessels ,
WMD