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US Administration’s § 231 List of Russian Entities Opens Some Third Parties to Potential Sanctions

Under the Act, secondary sanctions must be imposed on any US or non-US person, wherever located, that the US President determines has engaged in a “significant transaction” with any entity named on that list....more

Federal Criminal Case Raises Provocative Questions on US Jurisdiction

Can the US government criminally prosecute non-US persons for activities that constitute secondary Iranian sanctions violations with no alleged nexus to the United States?...more

Implications Arising from the Recent Venezuelan Sanctions

Though intended to avoid stifling trade in existing Venezuelan government bonds, the sanctions include restrictions on dealings in certain bonds that could impact bond holders....more

US President Issues Executive Order Imposing Additional Sanctions on North Korea

The executive order expands the extraterritorial reach of existing North Korea sanctions by extending it to US persons’ dealings with non-US actors that do business with North Korea....more

President Trump Announces Rollback on Obama-era Cuba Sanctions Easing

Changes to unwind will not take effect until new regulations are issued. On June 16, US President Donald Trump announced his decision to revoke some—but not all—of the relaxations in Cuba sanctions initiated under former...more

Legal Bases for Iran Sanctions, Cuba Sanctions, and NAFTA

How easily can the Trump administration change the status quo? The International Emergency Economic Powers Act (IEEPA), 50 U.S.C §§1701-1707 enacted October 28, 1977, authorizes the US president to broadly regulate...more

New York Mandates Economic Sanctions Compliance Program

The New York rule became effective January 1, 2017. The New York State Department of Financial Services (DFS) has issued a regulation that requires certain New York regulated financial institutions to maintain programs...more

US Imposes New Sanctions on Russia for Cyber-attacks

Five entities and six individuals were sanctioned for interference with the 2016 US election. On December 29, 2016, President Obama issued a new executive order that expands the authority of the US Secretary of Treasury...more

Considerations for Travel to Iran to Explore Relaxed Trade Opportunities

Before booking your airfare, be mindful of these potential issues. In light of liberalized trade with Iran made possible by the Office of Foreign Assets Control’s (OFAC’s) General License H and the relaxation of US...more

Export Regulation Revisions: Harmonization of Destination Control Statements

New rules synchronize Destination Control Statements for EAR and ITAR. On August 17, both the US Commerce Department’s Bureau of Industry and Security (BIS) and the US State Department’s Directorate of Defense Trade...more

OFAC Cites Violations in Dealings with Specially Designated Nationals

Insurance companies and financial institutions are targeted. On August 2, the US Department of the Treasury's Office of Foreign Assets Control (OFAC) issued a Finding of Violation against two different insurance...more

Iran Secondary Sanctions Relaxation: Effect on Shipping and Related Activities

Shipping companies should be mindful of restrictions that still apply. The relaxation of Iran sanctions that the United States implemented on January 16, 2016—“Implementation Day” for the Joint Comprehensive Plan of...more

“Implementation Day” Arrives, Triggering Relaxation of US Sanctions against Iran

The impact of Implementation Day will vary depending on whether you are a US Person, a US-owned or controlled Foreign Entity, or a Foreign Person with no US nexus—what’s your status? ...more

US Government Further Relaxes Trade Restrictions with Cuba

However, the new transaction rules leave the embargo largely in effect. Early this week, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Department of Commerce’s Bureau of Industry and...more

State Sponsor of Terrorism Amendment Made to EAR Regarding Cuba

Amendment triggers change in EAR de minimis level for controlled US-origin content in foreign made products. On April 14, US President Barack Obama submitted to Congress the statutorily required report indicating the...more

Switzerland Is the First Country to Lift Some Sanctions on Iran

Certain US sanctions on Iran may be lifted mid to late 2016 or even later. On August 13, Switzerland became the first country to formally lift certain sanctions on Iran, following the announcement of the Iran nuclear...more

Potential Upstream Investment Under the New Iranian Petroleum Contract

The signing of the JCPOA regarding Iran nuclear sanctions may usher in a new era of major international investment in the Iranian oil and gas industry....more

Executive Order Blocks Property of Those Engaging in Malicious Cyber Activities

The executive order enables US government agencies to block the assets of any foreign person determined to have engaged in malicious cyber-enabled activities....more

Certain Goods and Services Now Eligible for Importation into the United States from Cuba

The U.S. Department of State published its Section 515.582 List that outlines which goods and services produced by independent Cuban entrepreneurs are eligible for importation into the United States....more

3/5/2015

SEC Recommends "Localized" FCPA Controls For Foreign Subsidiaries

The SEC investigation found that the respondent lacked sufficient internal controls to prevent and detect approximately $230,000 in improper payments made by its China-based offices that falsely recorded the payments in books...more

3/5/2015

Partial Relaxation of Cuban Sanctions: New Regulations Issued

The U.S. Department of the Treasury and the U.S. Department of Commerce have released new regulations that loosen restrictions on trade and travel with Cuba....more

OFAC Sanctions Compliance Provisions in Various Agreements

Due to costly settlements secured by U.S. regulatory agencies, banks, insurers, and corporations are increasingly inserting rigorous OFAC sanctions compliance language into their credit agreements, insurance policies,...more

President Obama's New Executive Order Blocks Trade to Crimea

The executive order bans the export of goods, technology, and services to the Crimea region of Ukraine, but that’s not all it does. On December 19, 2014, U.S. President Barack Obama issued Executive Order #13685,...more

President Obama Announces Sweeping Changes to United States’ Diplomatic Relationship with Cuba

No changes in connection with the U.S. – Cuba embargo and sanctions will be effective until OFAC and the Commerce Department formally revise their respective regulations and general licenses to implement the President's new...more

New Senate Bill Significantly Expands U.S. Sanctions Against Russia

The bill, if passed, would impose severe sanctions on “foreign persons” that make significant investments in Russian crude oil projects....more

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