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BIS Revises Penalty and Settlement Guidance

On June 22, 2016, the Bureau of Industry and Security (“BIS”) revised its guidance regarding administrative enforcement cases for violations of the Export Administration Regulations (“EAR”), other than those related to...more

Implementation Day and the Lifting of Sanctions Against Iran

On January 16, 2016, the International Atomic Energy Agency confirmed that Iran had fulfilled its initial nuclear-related obligations under the Joint Comprehensive Plan of Action (JCPOA) that had been reached in July between...more

The Nuclear Deal With Iran: The Lifting of Sanctions and Implications for Business

On July 14, 2015, after two years of sometimes intense negotiations, the United States, the United Kingdom, France, Germany, Russia, and China (known as the “P5+1” countries), along with the European Union, signed a Joint...more

Where the Rubber Meets the Road: Obama Administration Announces Regulatory Amendments to U.S. Cuba Sanctions

On January 16, 2015, the U.S. Department of the Treasury (“Treasury”) amended the Cuban Assets Control Regulations, 31 C.F.R. Part 515 (“CACR”), and the U.S. Department of Commerce amended the Export Administration...more

Department of Commerce and OFAC Continue Imposing Hefty Sanctions on Russia, While Russia Retaliates with Own Sanctions

On August 6, the U.S. Department of Commerce (the “Commerce Department”) issued new regulations, implementing additional sanctions against Russia and introducing new restrictions on exports for its energy sector. These new...more

U.S. Imposes Further Economic Sanctions on Russian Officials and Entities in Connection with the Crisis in Crimea

On April 28, 2014, the Office of Foreign Assets Control (OFAC) imposed a new round of Ukraine-related sanctions on more than two dozen Russian companies and government officials. The latest sanctions, supplementing previous...more

The United States Increases - and, in One Case, Eases - Sanctions Against Iran

Most significantly, on June 3, 2013, President Obama issued Executive Order 13645 (78 Fed. Reg. 33945) that, effective July 1, 2013, implements provisions of the Iran Freedom and Counter-Proliferation Act of 2012 and imposes...more

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