Each quarter, we send many of our clients a quarterly trade compliance update, highlighting important developments over the last few months and summarizing key points for important sanctions programs. About the document: ...more
New announcements and rules expand the scope of existing sanctions and export controls on Russia. This Client Alert is published in the context of ongoing developments and should be read in conjunction with the Latham’s...more
In recognition of the one-year anniversary of Russia’s invasion of Ukraine, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) and US Department of Commerce’s Bureau of Industry and Security (BIS)...more
This update addresses the full implementation of the price cap policy for crude oil and petroleum products of Russian origin by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). On Feb. 3, OFAC...more
Ongoing tensions between the United States and China have resulted in an expansion of U.S. export controls and trade sanctions against China. The Biden Administration’s October 2022 National Security Strategy (“2022 NSS”)...more
Over the last week, the U.S. government, in coordination with partner and allied countries, announced a series of unprecedented escalating sanctions targeting Russia in response to the invasion of Ukraine. These actions...more
The new U.S. embargo on the breakaway Donetsk People’s Republic (DNR) and Luhansk People’s Republic (LNR) regions of Ukraine present U.S. companies with the complicated task of determining whether a transaction or account...more
Compliance Professionals: As the Ukraine braces for a possible Russian incursion, are you bracing for the impact of economic sanctions against Russia?...more
The Treasury Department’s Office of Foreign Asset Control (“OFAC”) continues to rack up settlements. Two travel insurance companies recently settled OFAC enforcement actions for violations of the Cuban Embargo....more
In a major announcement and escalation of the sanctions regime targeting President Maduro and Venezuela, on August 5, 2019, the Trump Administration issued a new Executive Order 13884 to block all property of the Venezuela...more
Dear Friend of Snell & Wilmer: The past year brought significant changes across a variety of political, legal, and policy spheres, and the world of U.S. international trade law was no exception. This edition of the...more
On Friday, June 16, President Trump announced policy changes towards Cuba while speaking in Miami. Trump’s new policy directive reverses many of the Obama administration’s policies with Cuba. ...more
According to reports published this week, the Trump Administration is preparing to release the results of its policy review on Cuba in the “coming weeks.” We don’t have a crystal ball (or a leaking insider). But we continue...more
As much of the world now knows, beginning in January 2015, the Obama Administration began easing some of the sanctions that have been imposed on Cuba for generations. Since that easing, there has been a great deal of interest...more
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 loosening of the U.S. trade embargo on Cuba has generated significant discussion regarding the country's potential for economic transformation. Most analysts agree that Cuba will be a very different country 10 years from...more
I continue my exploration of the issues raised under the Foreign Corrupt Practices Act (FCPA) when doing or attempting to do business in Cuba. On Monday, I referred to the one person I am aware of you might consult for advice...more
Cuba banned all private enterprise and foreign investment following Fidel Castro's 1959 revolution. For more than 50 years, the U.S. has imposed an almost total embargo on all trade with the largest Caribbean island nation. ...more
After President Obama's announcement that his Administration will pursue a policy aimed at improving U.S.-Cuba diplomatic relations and ultimately eliminating the economic embargo on Cuba, the U.S. Treasury and Commerce...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 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
Last week, President Obama announced plans for his administration to take historic steps to chart a new course in U.S.-Cuba diplomatic relations. Of the various components surrounding this ground-breaking policy approach, the...more
Historic changes in relations between the United States and Cuba (that touch nerves in Hip-Hop and on Capitol Hill) and new U.S. sanctions against Venezuela may provide increased opportunities for U.S. business generally, and...more
Against the backdrop of a dramatic prisoner swap and almost eighteen months of “secret” negotiations between the U.S. and Cuba—facilitated by Canada, the Vatican, and others—President Barack Obama announced on December 17,...more
President Obama recently announced changes to U.S.-Cuba policy, opening diplomatic relations with Cuba more than 50 years after the imposition of the Cold War-related sanctions against the country. The full scope of the...more