The New Cold War: Risk, Sanctions, Compliance Episode 22: "Focus on Iran: Protests, Sanctions and Oil"
Our International Trade team comments on additional restrictions on trade with Cuba
On August 27, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced amendments to two key FAQs (FAQs 736 and 757) concerning the Cuban Assets Control Regulations (“CACR”). These FAQs...more
Last week, the Office of Foreign Assets Control (OFAC) issued updates to the Cuban Assets Control Regulations (CACR). The updates are intended to continue the Biden administration’s policy of providing the Cuban people with...more
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
1. BIS Announces Plans To End Categorizing Emerging and Foundational Tech- On May 22, BIS announced in a proposed rule that it will end the effort to characterize specific technology as emerging or foundational for...more
The Cuban Assets Control Regulations have been amended to prohibit U.S. persons from lodging at certain properties in Cuba, incorporate restrictions on imports of Cuban alcohol and tobacco, and revoke general licenses...more
OFAC announced a $257k settlement with Biomin America, Inc. (“Biomin”), an animal nutrition company based in Overland, Kansas, to settle violations of the Cuban Sanctions Program....more
The Trump Administration announced a more restrictive policy towards Cuba in a presidential memo issued in June 2017. Since then, the Administration has implemented initiatives that have narrowed or revoked authorized trading...more
On October 21, 2019, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) imposing new sanctions on Cuba for human rights abuses and for its support of...more
BIS has restricted Cuba’s access to commercial aircraft and other goods, lowered de minimis for foreign items containing US content to 10%, and restricted the temporary sojourn by aircraft in Iran, Syria, Sudan, and North...more
On September 9, 2019, the Trump administration implemented additional U.S. sanctions on Cuba by restricting personal remittances to Cuba and eliminating authorization for U.S. banks to process “U-turn” transactions involving...more
• Yesterday, May 2, the United States government allowed implementation of Title III of the Helms-Burton Act, for the first time since the law was enacted in 1996, to permit U.S. nationals to sue persons that “traffic” in...more
In 2018, the United States continued to expand its sanctions programs and increase enforcement. While President Donald Trump’s decision to re-impose nuclear-related sanctions on Iran has perhaps drawn the most attention, key...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
The Office of Foreign Assets Control has amended the Cuban Assets Control Regulations to implement changes to the Cuba sanctions program announced by President Trump in June of this year, which aimed to reinforce certain...more
On November 9, 2017, the US Departments of the Treasury and Commerce implemented President Trump's June 2017 National Security Presidential Memorandum (NSPM) that was designed to tighten restrictions on individual travel to...more
On 9 November 2017, the Trump Administration implemented new regulations to support its change to U.S. policy on Cuba. The U.S. Government has created a new Cuba Restricted List administered by the State Department. Through...more
On June 16, 2017, President Trump announced revisions to U.S. policy toward engagement with Cuba and a limited rollback of certain sanctions relief provided by the Obama Administration....more
On December 17, 2014, President Obama announced that the United States would “chart a new course” on its Cuba policy. Starting in January 2015, and for the next two years, the Treasury Department’s Office of Foreign Assets...more
On June 16, 2017, President Trump announced new sanctions restrictions under the US embargo against Cuba. Although US policy since 2014 has been to normalize US-Cuba relations and liberalize trade with Cuba, President Trump...more
ANTICORRUPTION DEVELOPMENTS - Las Vegas Sands Corporation Agrees to Pay Approximately $7 Million to Resolve DOJ FCPA Enforcement Action – On January 19, 2017, Las Vegas Sands Corporation (“Sands”), a Nevada-based...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
With the results in from the U.S. presidential election, companies should begin to consider the potential impact of a Trump presidency on their international business. U.S. economic sanctions were among the hot-button issues...more