News & Analysis as of

BIS

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

U.S. Sanctions Developments in the Trump Administration

by BakerHostetler on

The Trump Administration has been active on the sanctions front as a means of asserting United States foreign policy and national security interests. Congress has also taken an increasingly active and direct role of late,...more

November 2017 Update on Significant DOT, FAA and Other Federal Agencies’ Aviation-Related Regulatory Actions

by Cozen O'Connor on

This edition of the Cozen O’Connor Aviation Regulatory Update discusses new restrictions on Cuba travel, DOT’s Small Community Air Service Development Grant Program, new DOT drug testing requirements for safety-sensitive...more

Information filtration under the Export Administration Regulations

by Miller Canfield on

Information provides the cornerstone to the modern economy. Information flows across information technology networks similar to water naturally flowing down our mountains, into our streams and rivers, and out to the oceans....more

US implements key changes to Cuba sanctions financial transactions and travel provisions

by Dentons on

Effective November 9, 2017, the US Department of Treasury’s Office of Foreign Assets Control (OFAC) and the US Department of Commerce’s Bureau of Industry and Security (BIS) amended the Cuban Assets Control Regulations (CACR)...more

OFAC Increases Clarity Regarding Financial Transactions with Cuba

by Ballard Spahr LLP on

On November 9, 2017, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) amended the Cuban Assets Control Regulations, 31 C.F.R. part 515 (the “CACR”), with the stated intent of channeling economic...more

Cuba Sanctions Guidance: November 2017 Update

by Baker Donelson on

On November 9, 2017, changes to the United States' Cuba Sanctions program went into effect, as the Department of Treasury's Office of Foreign Assets Control (OFAC) and the Department of Commerce's Bureau of Industry and...more

Changes to Cuba Sanctions Program Pursuant to National Security Presidential Memorandum

by Alston & Bird on

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

New Sanctions Placed on Trade with Cuba

by Kelley Drye & Warren LLP on

On Thursday November 9th, the Office of Foreign Assets Control (“OFAC”) published new regulations in the Federal Register executing June’s National Security Presidential Memorandum (“NSPM”) regarding U.S. sanctions against...more

U.S. Government Agencies Publish Changes to Cuba Sanctions Program Pursuant to President Trump’s Policy Announcement

On November 8, 2017, the Department of Treasury’s Office of Foreign Assets Control (“OFAC”) and the Department of Commerce’s Bureau of Industry and Security (“BIS”) announced amendments to the Cuban Assets Control Regulations...more

BIS Clarifies Use of License Exceptions GOV and STA

On November 1, 2017, the Department of Commerce’s Bureau of Industry and Security (BIS) introduced clarifications to the Export Administrative Regulations (EAR) for the use of license exception “Governments, International...more

Red Notice Newsletter - October 2017

ANTICORRUPTION DEVELOPMENTS – Global Compliance Overhaul for SAP as DOJ and SEC Investigate Payments Allegedly Related to South African Government Contracts – On October 26, 2017, German software company SAP SE...more

Cuba Policy Shift Stalls as Businesses Await OFAC Implementation

by Baker Donelson on

On June 16, 2017, President Trump issued a National Security Presidential Memorandum on Strengthening the Policy of the United States Toward Cuba. The Memorandum outlined a framework for agencies such as the Treasury...more

United States Eases Sudan Sanctions

by White & Case LLP on

After 20 years of comprehensive sanctions against Sudan, the US government has revoked most sanctions with respect to Sudan and the Government of Sudan effective October 12, 2017. As a result of this action, US persons1 are...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

Census Begins Review of Routed Export Reporting Requirement

• The U.S. Bureau of the Census has issued a notice requesting comments on the definition of “routed export transaction” and the responsibilities of parties in routed export transactions. Comments are due by December 5,...more

US Revokes Sudan Sanctions

On October 6, 2017, President Donald Trump and the U.S. Department of State announced the revocation of economic sanctions on Sudan, following the temporary lifting of sanctions on January 17, 2017. The announcement concluded...more

Time to Review Your Encryption Classifications – BIS Updates Primary Purpose Exemption

by Kelley Drye & Warren LLP on

The Bureau of Industry and Security (BIS) recently published changes to its encryption regulations in an effort to simplify the text and focus the scope of controls. The biggest change is that Note 4, the “primary purpose...more

Trump Tightens Cuba Sanctions

by King & Spalding on

On June 16, 2017 President Trump announced new policy parameters for the U.S.-Cuba relationship and directed the Office of Foreign Assets Control (OFAC), Department of Treasury, Bureau of Industry and Security (BIS),...more

President Trump Announces Changes to Cuba Policy

by Cozen O'Connor on

On June 16, 2017, President Trump announced changes to the U.S. policy toward Cuba aimed at tightening travel restrictions on U.S. persons and limiting the Cuban military’s access to U.S. dollars. Although announced on June...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

Update on Regulatory Compliance in the Global Health Care Industry

by Baker Ober Health Law on

A comprehensive understanding of the constantly evolving layers that make up federal anti-corruption statutes, sanctions regulations and export control restrictions is imperative for both the pharmaceutical and health care...more

Top 10 Red Flags for Potential Export Violations

by Tucker Arensberg, P.C. on

If your business exports goods or services, it cannot afford to run afoul of the Commerce Department’s Export Administration Regulations (EAR). Criminal penalties can reach up to 20 years imprisonment and $1 million per...more

The ZTE Case: U.S. Sanctions and Export Control Laws

by Benesch on

The settlement reached by China’s giant telecommunication company, ZTE Corporation (“ZTE”) with various U.S. government agencies, including U.S. Attorney’s Office, U.S. Department of Justice, U.S. Department of Commerce’s...more

Trump Administration investigating national security implications of certain steel and aluminum imports

by Dentons on

On April 19, 2017, Commerce Secretary Wilbur Ross initiated an investigation on the effects of steel imports on US national security, under Section 232 of the Trade Expansion Act of 1962 (19 USC § 1862). The next day,...more

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