News & Analysis as of

Office of Foreign Assets Control

Implementing CAATSA Sanctions on Russia: Approaching Deadlines for “Oligarchs” and “Sovereign Debt” Reports and Recap of Latest...

• The next significant Countering America’s Adversaries Through Sanctions Act (CAATSA)-related deadline for the Trump administration is January 29, 2018, when it must submit reports to Congress on “oligarchs and parastatal...more

OFAC Issues Statement On Venezuelan Digital Currency

by Goodwin on

On Friday, the Office of Foreign Assets Control (OFAC) issued FAQ 551 stating that U.S. persons who deal in the prospective Venezuelan digital currency (the “Petro”) may be exposed to U.S. sanctions risk under Executive Order...more

Going to get paid in Venezuelan cryptocurrency? Not so fast.

by Kelley Drye & Warren LLP on

In December last year, Venezuelan President Nicolas Maduro announced that Venezuela would launch a cryptocurrency called “Petro” in an effort to ease the country’s serious economic woes and avoid U.S. sanctions. Maduro said...more

Trade & Manufacturing - News of Note - January 2018

by King & Spalding on

The United States Trade Representative (USTR) issued a request for comments and notice of public hearing regarding the 2018 Special 301 Review. The review is a Congressionally-mandated annual review of the global state of...more

Status of the Iran Nuclear Deal and New Sanctions Designations

On January 12, 2018, President Trump issued a statement on the status of the Joint Comprehensive Plan of Action (“Iran nuclear deal”) and the Office of Foreign Assets Control designated 14 individuals and entities in...more

U.S. Targets Human Rights Abusers and Corrupt Actors Worldwide – Key Takeaways from the Potent New Sanctions

On December 20, 2017, President Trump issued Executive Order 13818 (the “E.O.”) implementing provisions of the Global Magnitsky Human Rights Accountability Act (“Global Magnitsky Act”) (enacted into law in December 2016),...more

U.S. Dental Supply Company Penalized for Violating Iran Sanctions

by Bass, Berry & Sims PLC on

•Many medical products can be exported to Iran – so long as a license is obtained •Imposition of successor liability underscores importance of pre-transaction due diligence •OFAC enforcement, as in the past, continues...more

Red Notice Newsletter - Russian

ANTICORRUPTION DEVELOPMENTS – Keppel Offshore Reaches Deal with DOJ and Guilty Plea by Counsel Unsealed – On December 22, 2017, Keppel Offshore & Marine Ltd. (KOM), a Singapore based company that operates shipyards and...more

Red Notice Newsletter - Chinese

ANTICORRUPTION DEVELOPMENTS – Keppel Offshore Reaches Deal with DOJ and Guilty Plea by Counsel Unsealed – On December 22, 2017, Keppel Offshore & Marine Ltd. (KOM), a Singapore based company that operates shipyards and...more

Sanctions Round Up: Fourth Quarter 2017

by Shearman & Sterling LLP on

Headlines from the final months of 2017 included the signing of a new executive order with global anti-corruption implications; new guidance on the Trump Administration’s approach to Russia sanctions under CAATSA; tightening...more

U.S. Implements Global Magnitsky Sanctions Targeting Corruption and Human Rights Abuses Worldwide

by Kelley Drye & Warren LLP on

On December 20, 2017, the President issued Executive Order 13818 implementing new sanctions against human rights abusers and persons involved in corruption pursuant to the Global Magnitsky Human Rights Accountability Act...more

New Sanctions Imposed For Human Rights Abuses and Corruption – a Harbinger For Business in 2018?

by Baker Donelson on

On December 21, the U.S. Treasury Department announced the implementation of a new global sanctions regime under the Magnitsky Human Rights Accountability Act (the “Global Magnitsky Act”). President Trump issued an Executive...more

Global Magnitsky Act and Magnitsky Act Designations: same old song, or change of tune?

by Hogan Lovells on

On December 20, 2017, President Trump issued Executive Order 13818 implementing the Global Magnitsky Act, and the Office of Foreign Assets Control (OFAC) issued the first designations responsive to this statute. Please...more

Trump Administration Establishes New Sanctions Regime Targeting Human Rights Abusers - Also Expands Existing Sanctions on...

by Holland & Knight LLP on

The Trump Administration rounded out the year with two sanctions-related actions: The first involved creating a new program regarding human rights abusers and global corruption; the second involved adding several individuals...more

Red Notice Newsletter - December 2017

ANTICORRUPTION DEVELOPMENTS – Keppel Offshore Reaches Deal with DOJ and Guilty Plea by Counsel Unsealed – On December 22, 2017, Keppel Offshore & Marine Ltd. (KOM), a Singapore based company that operates shipyards...more

OFAC Designates Diamond Mining Billionaire, “Thieves in Law,” and Many Other International Targets as Subject to U.S. Sanctions...

by Ballard Spahr LLP on

The Office of Foreign Assets Control (“OFAC”) wrapped up 2017 by issuing a series of high-profile designations generally prohibiting U.S. persons from conducting financial or other transactions with the identified individuals...more

Trump Administration Announces Sanctions Pursuant to the Global Magnitsky Act

On December 21, 2017, the Trump Administration released a list of foreign nationals it has identified to be sanctioned in accordance with the Global Magnitsky Human Rights Accountability Act of 2016. In December 2016, we...more

Global Magnitsky Sanctions Target Human Rights Abusers and Government Corruption Around the World

by WilmerHale on

On December 20, 2017, President Trump issued a new Executive Order (EO) targeting corruption and human rights abuses around the world. The EO implements last year's Global Magnitsky Human Rights Accountability Act (the...more

Treasury, State and Commerce Implement Regulations Pursuant to the Trump Administration’s Cuba Policy

• 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

Iran Sanctions Update: No Change for Companies as Pressure Shifts Back to President Trump as Key Deadline Passes

by Baker Donelson on

On December 12, a key deadline passed for Congress to reimpose nuclear-related sanctions against Tehran, shifting the pressure back to the executive branch and setting new deadlines that will be critical to the fate of the...more

How to Throw a Festive Law Firm Holiday Party

by Knapp Marketing on

Lawyers are a competitive bunch. For these minds, mulling around the mulled cider does not a stimulating holiday party make. So this holiday season, we treated our law firm clients to some Christmas-themed legal debates on...more

Best Practices for Compliance with North Korea OFAC Sanctions

by Baker Donelson on

As we discussed further at length, the U.S. and nations around the world have recently sought to implement and impose harsh economic sanctions programs against North Korea to pressure Pyongyang into ceasing its development...more

Venezuela Debt Restructuring – Sanctions Compliance

As parties pursue restructuring of Venezuelan sovereign debt, they should be sensitive to U.S. economic sanctions prohibitions. The sanctions prohibitions broadly apply to "U.S. persons" – U.S. citizens and permanent...more

Latin America Dispute Resolution Update – The Latest Developments in Cross-Border Disputes Involving the US and Latin America

NAFTA’s Future Looks Increasingly Uncertain - The United States, Mexico and Canada have now completed the fifth round of negotiations concerning the renegotiation of NAFTA, and the future of the treaty is looking...more

Distributor danger: OFAC case highlights sanctions liability for bad acts by distributors and foreign subsidiaries

by Kelley Drye & Warren LLP on

Many companies supply goods and services through third party distributors. When well-structured, the use of distributors can shift some of the cost and compliance risk of selling products outside of your home territory. But...more

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Cybersecurity

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