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Newly Amended Dual Agency Disclosure Law: Much Ado About Nothing
The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) amended the Cuban Assets Control Regulations (CACR), 31 CFR Part 515, to promote internet freedom in Cuba, support independent Cuban private-sector...more
On December 13, 2019 the Department of Justice (“DOJ”) announced a major revision of its voluntary disclosure program for criminal violations of U.S. export and sanctions laws. Under the new policy (the “Policy”), if a...more
On December 13, 2019, the National Security Division (NSD) of the U.S. Department of Justice (DOJ) issued a revised policy regarding voluntary disclosure of export control and sanctions violations by business organizations...more
Ambiguous, undefined terms create uncertainty and confusion, including whether owned or controlled subsidiaries of U.S. companies outside the United States are subject to this reporting requirement. On June 21, the...more
On Friday, March 15, 2019, the Government of Canada amended its Russia economic sanctions regulations to add a number of new individuals and entities to the restricted party list. See Regulations Amending the Special Economic...more
On July 25, 2017, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) issued a revised set of frequently asked questions (FAQs) further clarifying the scope and implementation process for the...more
To further implement President Obama's December 2014 policy to support independent economic activity and improve communications and living conditions in Cuba, the U.S. Department of Commerce's Bureau of Industry and Security...more
Ten key changes to US sanctions and export regulations for Cuba. On January 15, 2015, the Departments of the Treasury and Commerce revised the Cuban Assets Control Regulations (CACR) and the Export Administration...more
The Obama administration recently announced the most significant changes in years to U.S. sanctions against Cuba, allowing expanded travel, trade, and exchange in targeted areas....more
As part of a broader, ongoing effort to forge closer relations with Cuba, the Obama administration has enacted a new set of regulations intended to facilitate certain forms of authorized travel to Cuba. The regulations, which...more
On January 16, 2015, the Office of Foreign Assets Control, U.S. Department of the Treasury (“OFAC”), and the Bureau of Industry and Security, U.S. Department of Commerce (“BIS”), each published regulations implementing the...more
Action Item: On January 16, 2015, the U.S. Department of the Treasury’s Office of Foreign Assets Control and the U.S. Department of Commerce amended the Cuban Assets Control Regulations and the Export Administration...more
On January 15, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) released important updates to the Cuban Assets Control Regulations (“CACR”). The U.S. Department of Commerce’s Bureau of Industry...more
New Rules Open Opportunities for Exports, Financial Services, and Travel- On January 16, 2014, the U.S. Treasury Department issued new sanctions regulations easing the 54-year old Cuban embargo. Coming in the wake of...more
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
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
As promised by President Obama in December 2014, the Commerce Department's Bureau of Industry and Security (BIS) and the Treasury Department's Office of Foreign Assets Control (OFAC) today issued regulations that lessen the...more
Since the 1960s, the United States has maintained an embargo on Cuba that in many respects is the most comprehensive set of economic and trade restrictions on any country. On January 16, 2015, amendments to regulations issued...more
Today, the Department of Treasury’s Office of Foreign Assets Control (OFAC) amended the Cuban Assets Control Regulations to implement changes in U.S. policy toward Cuba announced by President Obama on December 17, 2014....more