U.S. policy reversal allows suits in U.S. courts and visa denials, for “trafficking” in confiscated property in Cuba
In too many ways to count, 2020 was an extraordinary year. As we move into 2021 with optimism for an end to the pandemic and better days ahead, we understand that the activity last year of the U.S. Department of the...more
IN THIS ISSUE • Anticorruption Developments • Export Control Sanctions and Customs Enforcement • Export Control and Sanctions Developments • Global Investigations Resources • Writing and Speaking Engagements ...more
• On November 9, 2017, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), the U.S. Department of State, and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) took coordinated...more
The Situation: Regulations implementing tightened U.S. policy towards engagement with Cuba have rolled back a number of Obama-era initiatives and are effective immediately. The Result: Provisions that encourage Cuban...more
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
The Trump Administration has made good on its promise to cut back on the liberalized Cuban policy implemented by the Obama Administration with a new regime that introduces new travel restrictions as well as broad prohibitions...more
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
On the afternoon of June 16, 2017, shortly before President Donald Trump announced new changes to the U.S.-Cuba policy, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) issued 12 frequently asked...more
- Canadian bank pays penalties for U.S. dollar transactions involving Cuba and Iran - Bank receives Finding of Violation – but no penalty – for violations by European subsidiaries - Disclosure and cooperation...more
U.S. embargoes and economic sanctions on countries such as Iran, Russia and Cuba were discussed at length by both candidates during the 2016 Presidential campaign, and President-Elect Trump has stated that he intended to...more
On October 17, 2016 the U.S. Office of Foreign Assets Control (OFAC) and the U.S. Department of Commerce's Bureau of Industry and Security (BIS) published respective amendments to the Cuban Assets Control Regulations and...more
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
On October 14, 2016, the Treasury Department’s Office of Foreign Assets Control (OFAC) and the Commerce Department’s Bureau of Industry and Security (BIS) published another round of amendments to the Cuban Assets Control...more
With fewer than 100 days left in office, President Obama is not slowing down on his efforts to normalize relations between the United States and Cuba. Today, several changes to the Cuban Assets Control Regulations (CACR) and...more
Both the U.S. Treasury’s Office of Foreign Assets Control (OFAC) and the Department of Commerce’s Bureau of Industry and Security (BIS) have announced new amendments to the Cuban Assets Control Regulations (CACR) and Export...more
The Department of Treasury and Department of Commerce have made several changes to the Cuban Assets Control Regulations (CACR) and the Export Administration Regulations (EAR) since the Administration announced its new...more
We all know that export regulations cannot keep up with reality. Reforms are happening very quickly, especially regarding Cuba. So, here’s a new procedure we just discovered. Perhaps it can help you if you are ever similarity...more
The Office of Foreign Assets Control (OFAC) updated its FAQs for Cuba on April 21, 2016 with substantive guidance that addresses U-turn transactions, export policy, insurance, educational and humanitarian activities and...more
In advance of President Obama’s highly publicized trip to Cuba, the Administration took additional steps to ease restrictions on trade and travel with Cuba. These changes to the Cuban Assets Control Regulations (CACR) and...more
The Department of Treasury’s Office of Foreign Assets Control (OFAC) and the Commerce Department’s Bureau of Industry and Security (BIS) have respectively published another round of amendments to the Cuban Assets Control...more
Why it matters - Continuing to ease the restrictions on financial relationships with Cuba, the Department of the Treasury's Office of Foreign Assets Control (OFAC) announced additional policy changes to "remove existing...more
On January 25, the Obama Administration made concurrent announcements about its evolving posture on the Cuban sanctions. On that date, the Office of Foreign Assets Control (OFAC) released more changes to the Cuban Assets...more
For over 50 years, the ability to travel to Cuba and do business or trade with Cuban nationals has been governed by a byzantine set of regulations administered by the Department of Treasury’s Office of Foreign Assets Control...more
Policy changes announced by the Obama administration on September 18 will allow U.S. food and agriculture companies, U.S. telecommunications companies and U.S. building material supplier companies to establish a business...more