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U.S. State Department Issues Belated List and Guidance on Extraterritorial Sanctions Affecting Russian Defense and Intelligence...

• On October 27, 2017, the U.S. State Department issued guidance identifying 39 entities related to the defense and intelligence sectors of the Government of the Russian Federation and issued related guidance on criteria to...more

Trump Administration Lifts U.S. Sanctions on Sudan; Important Limitations Remain

Based on certain State Department findings, effective October 12, 2017, long-standing U.S. sanctions on the Republic of Sudan administered by OFAC under the Sudan Sanctions Regulations will be terminated, and U.S. persons...more

Implementing CAATSA - OFAC Issues Amended Russian-Related Sectoral Sanctions Under Directives 1 and 2

On September 29, 2017, OFAC modified Directives 1 and 2 of Executive Order 13662 to reduce the permissible maturity for new debt issued by Russian financial and energy entities designated under these directives, as well as...more

Russia Sanctions - EU Expands Sanctions Following Alleged Diversion of Siemens Turbines

On August 4, 2017, the Council of the European Union (the “Council”) made six new designations to the list of persons subject to restrictive measures in respect of actions undermining or threatening the territorial integrity,...more

Cuba Sanctions: President Trump Announces Tightening of U.S. Sanctions While Maintaining Certain Sanctions Relief Implemented by...

On June 16, 2017, the Trump administration issued a national security presidential memorandum entitled “Strengthening the Policy of the United States Towards Cuba” (the “Presidential Memorandum”). Related to this...more

OFAC Eases Certain Sanctions Involving Russia’s FSB; BIS Licensing Still Required

On February 2, 2017, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Cyber-related General License (GL) 1, a general license that authorizes certain transactions with Russia’s Federal...more

2016 Postelection Regulatory Report

The results of the U.S. presidential election are historic and unanticipated, and they will have significant economic, political, legal and social implications. As we prepare for the Trump presidency, many uncertainties...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

Burma Sanctions Lifted—Political and Reputational Risks Remain

If you read one thing… - On October 7, 2016, President Obama issued an Executive Order that effectively eliminates sanctions against Myanmar (referred to as Burma by the White House) and removes the sanctions...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

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

9/9/2016  /  BIS , OFAC , Russia , Sanctions , SDN List , SSI List , Ukraine

Cuba Natural Gas

CNG – Cuba Natural Gas - With the recent shift in U.S. government policy regarding Cuba, is now the time for the energy industry, particularly liquefied natural gas (LNG) project developers, to consider Cuba?...more

Anti-Corruption Summit: Extending Corporate Liability for Economic Crimes?

In a keynote address at the London Anti-Corruption Summit, Prime Minister David Cameron raised the possibility of new U.K. legislation to make corporations liable for “failure to prevent” fraud or money-laundering offenses...more

Cuba on Trend: Chanel Hosts Fashion Show in Havana as Diplomatic and Cultural Relations Continue to Open with Cuba

On May 3, French fashion house Chanel hosted the first international fashion show in Cuba since the 1959 communist revolution. The Resort 2017 show was held open-air in Paseo del Prado, one of the city’s central streets. It...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

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

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