News & Analysis as of

Office of Foreign Assets Control

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 Office of Foreign Assets Control Amends Cuba Sanctions Program, Implementing Trump Directive

by Shearman & Sterling LLP on

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

The US Revises Commercial and Travel Sanctions Against Cuba

by WilmerHale on

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

U.S. Issues Enhanced Sanctions on Russian Energy Sector

by Kelley Drye & Warren LLP on

As required under recent sanctions legislation, the U.S. Office of Foreign Assets Control (OFAC) issued an updated Directive 4 last week that will expand sectoral sanctions on the Russian energy industry. The new rules,...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

Evolving U.S. and UN Sanctions Against North Korea

Following President Trump’s trip to Asia, sanctions policies for North Korea continue to evolve. The U.S. government has strengthened sanctions through legislation and Presidential Executive Orders. Further, it is enforcing...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

Cuba update: Trump tightens travel authorizations and targets new restricted parties

by Hogan Lovells on

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

U.S. Government Issues Guidance on Expanded Russia Sanctions

by Holland & Knight LLP on

• The U.S. Department of State issued public guidance on sanctions with respect to 39 named entities related to Russia's defense and intelligence sectors. This guidance is issued under Section 231 of the Countering America's...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

Trump Administration Sets Approach to Implementation of New Russia Sanctions

In recent weeks, the U.S. government has taken a number of significant steps to implement sanctions on Russia under the Countering America’s Adversaries Through Sanctions Act (CAATSA), which President Donald Trump signed into...more

Venezuela Restructuring: A Long Road Ahead?

by Latham & Watkins LLP on

Venezuela’s initiative is unlikely to set the stage for a restructuring of international obligations in the face of US sanctions. Key Points: - US sanctions will prohibit US persons from engaging in a restructuring of...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

Status of Key U.S. Sanction Programs

by Miller Canfield on

Recently, many revisions to U.S. sanction programs (both implemented and under consideration) have been the topic of much public discussion. Often, the legal status or these revisions may be difficult to determine....more

Russia Sanctions under CAATSA – U.S. Updates Rules and Provides Guidance on Enforcement

This week, the U.S. government took several steps to implement sections of the Countering America’s Adversaries Through Sanctions Act of 2017 (CAATSA), with implications for Russia-related sanctions and their enforcement. On...more

State Department Identifies Parties Operating in Defense and Intelligence Sectors of Russian Federation

by White & Case LLP on

On October 27, 2017, the US Department of State issued public guidance on the implementation of Section 231 of the Countering America’s Adversaries Through Sanctions Act of 2017 (CAATSA). CAATSA requires the imposition of...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

Iran: Following President Trump’s “Decertification,” New U.S. Sanctions on Iranian Entities and All Eyes on the U.S. Congress

• Effective October 13, 2017, President Trump declined to provide certification that the JCPOA is in the United States’ national interest. Following this “decertification,” the U.S. Congress has 60 days in which to introduce...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

Sudan Sanctions Revocation Formalized, But Compliance Challenges Remain

by Baker Donelson on

On October 12, 2017, the Treasury Department’s Office of Foreign Assets Control (OFAC) revoked certain parts of its economic sanctions regime with respect to Sudan and the Government of Sudan. OFAC issued a General License...more

A UK Version of OFAC?

The Office of Financial Sanctions Implementation ramps up enforcement activities in London - A new UK sanctions enforcement body with added civil enforcement tools is ramping up activities. ...more

U.S. State Department Issues Belated List and Guidance on Extraterritorial Sanctions Affecting Russian Defense and Intelligence...

• On October 27, 2017, the U.S. State Department issued guidance identifying 39 entities related to the defense and intelligence sectors of the Government of the Russian Federation and issued related guidance on criteria to...more

Iran Speech Shifts Pressure to Congress, But Changes Little for U.S. Businesses

by Baker Donelson on

President Trump’s October 13 speech denounced Iran’s “fanatical regime” as a “menace,” and threatened to terminate the 2015 Iran nuclear deal negotiated by Barack Obama and formally known as the Joint Comprehensive Plan of...more

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Cybersecurity

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