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In Directional Shift, US Implements New Restrictions on Cuba

On November 8, 2017, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC), the U.S. Department of Commerce's Bureau of Industry and Security (BIS), and the U.S. Department of State announced...more

Trump Administration Sets Approach to Implementation of New Russia Sanctions

In recent weeks, the U.S. government has taken a number of significant steps to implement sanctions on Russia under the Countering America’s Adversaries Through Sanctions Act (CAATSA), which President Donald Trump signed into...more

President Trump 'Decertifies' the JCPOA, but the US Remains a Party to the Deal

Pursuant to the Iran Nuclear Agreement Review Act of 2015 (INARA), the president is required to make certifications every 90 days that Iran is complying with its obligations under the Joint Comprehensive Plan of Action...more

US Dramatically Increases Sanctions on North Korea

On September 21, 2017, President Donald Trump issued Executive Order (E.O.) 13810, which broadly expanded U.S. sanctions against North Korea. E.O. 13810 targets, among others, individuals and entities that are part of certain...more

Federal Reserve Board Publishes Request for Comment on LIBOR Alternatives

On August 30, 2017, the Federal Reserve Board published in the Federal Register its request for comment on proposed plans for the Federal Reserve Bank of New York and the Office of Financial Research to publish three new...more

New Sanctions Target the Government of Venezuela's Access to US Capital Markets

On August 25, 2017, the U.S. government dramatically increased sanctions on the government of Venezuela. Unlike the Venezuela-related sanctions already in effect, which are list-based and to date have targeted only specific...more

Federal Reserve Board Seeks Public Comment on Alternatives to LIBOR

The U.S. Federal Reserve Board is requesting public comment on proposed plans for the Federal Reserve Bank of New York and the Office of Financial Research to publish three new reference rates intended as alternatives to the...more

"UK Tracks OFAC Model in Issuing Guidance on Monetary Penalties for Breaches of Financial Sanctions"

As previously reported, the Policing and Crime Act 2017 (the Act) introduced a series of major changes to the U.K. financial sanctions regime. The changes, which came into force on April 1, 2017, included the creation of new...more

"US Announces Record-Setting Penalties for Violations of Export Controls and Economic Sanctions"

On March 7, 2017, the United States announced that China’s Zhongxing Telecommunications Equipment Corporation and ZTE Kangxun Telecommunications Ltd. and their respective affiliates (collectively, ZTE) had agreed to a record...more

"Future of Sanctions on Iran, Russia and Cuba Uncertain Under Trump"

Throughout the eight years of the Obama administration, the development and implementation of economic sanctions was a key element of U.S. foreign and national security policy. This strategy continued into the post-election...more

"The Trump Impact: Key Issues in Financial Services Reform for 2017"

The Trump administration has provided few specifics regarding its plans for financial regulatory reform. But Republican control of the executive and legislative branches of the federal government should create a favorable...more

"US Announces Tentative Lifting of Sudan Sanctions; OFAC Issues Guidance on Providing Sanctions Advice"

On January 13, 2017, President Obama and the Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced the interim lifting of sanctions on Sudan, with a path to a permanent revocation of sanctions in six...more

"OFAC Eases Restrictions on the Export of Medical Devices to Iran"

On December 22, 2016, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced amendments to the general license (GL) that authorizes the export or re-export of certain medical devices to Iran....more

"Federal Regulator Signals Willingness to Grant National Bank Charters to Fintech Companies"

On December 2, 2016, the Office of the Comptroller of the Currency (OCC) announced its willingness to entertain applications from financial technology (fintech) companies for special purpose national bank charters. In recent...more

"OFAC and BIS Implement Additional Amendments in Support of Cuba Policy Shift"

On October 14, 2016, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Department of Commerce’s Bureau of Industry and Security (BIS) announced further amendments to ease U.S. sanctions and...more

After Nearly 20 Years, US Lifts Burma Sanctions

After nearly two decades, the United States has formally ended economic sanctions on Burma (Myanmar). Citing substantial efforts undertaken to promote democracy, President Barack Obama issued an executive order, on October 7,...more

Privacy & Cybersecurity Update: New York State Proposes Cybersecurity Regulation for Financial Institutions

New York state has proposed a new regulation — to go into effect January 1, 2017 — that would require banks, insurance companies and other financial services institutions regulated by the New York State Department of...more

"NYDFS Finalizes Rule to Regulate Transaction Monitoring, Filtering"

Financial institutions operating in New York — including New York state licensed banks, trust companies, private bankers, savings banks, savings and loan associations, branches of foreign banks, check cashers, and money...more

"US Further Eases Burma Sanctions"

In response to Burma’s peaceful and competitive elections in November 2015, on May 18, 2016, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) further eased U.S. sanctions against Burma (Myanmar). These...more

"FinCEN Finalizes Customer Due Diligence Rule Amid Other Actions to Enhance Financial Transparency"

In the wake of the Panama Papers controversy, the U.S. government has taken major steps this month to promote financial transparency. First, the Financial Crimes Enforcement Network (FinCEN) finalized its proposed rule issued...more

"UK Establishes New HM Treasury Office to Implement Financial Sanctions"

On March 31, 2016, the U.K. launched the new Office of Financial Sanctions Implementation (OFSI) within HM Treasury. OFSI, which assumes the financial sanctions responsibilities previously carried out by HM Treasury’s Asset...more

"US Further Eases Sanctions Ahead of President’s Historic Trip to Cuba"

On March 15, 2016, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Department of Commerce’s Bureau of Industry and Security (BIS) announced regulatory amendments that further eased U.S....more

"OFAC and BIS Ease Cuba Restrictions With New Amendments"

On January 27, 2016, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Department of Commerce’s Bureau of Industry and Security (BIS) further eased U.S. sanctions and export control regulations...more

‘Implementation Day’: Key Aspects of US and EU Implementation of Iran Sanctions Relief

On January 16, 2016, the International Atomic Energy Agency verified that Iran had complied with the nuclear-related technical aspects of the Joint Comprehensive Plan of Action it had to complete before the first phase of...more

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