News & Analysis as of

Office of Foreign Assets Control

Top 10 Topics for Directors in 2018

EXECUTIVE SUMMARY - 1. Cybersecurity threats. Cybersecurity preparedness is essential in 2018 as the risk of, and associated adverse impact of, breaches continue to rise. The past year redefined the upward bounds of the...more

October and November Developments

by Sullivan & Worcester on

For the first time in my memory, the Congress passed a joint resolution to disapprove a final regulation of a federal agency—in this case the CFPB and the rule was related to arbitration clauses in contracts for consumer...more

With Mugabe's Departure, Should Foreign Investors Reconsider Zimbabwe?

by Jones Day on

The Situation: In November 2017, Robert Mugabe, the only leader Zimbabwe had known in 37 years, was ousted from power. The Development: Will this change in leadership usher in a new era of good governance and economic...more

Sanctions Updates: Cuba, North Korea, Russia, Sudan, Venezuela

by Michael Volkov on

Sanctions compliance is challenging because of the changing nature of sanctions regulations and individuals identified as Specially Designated Nationals. With each new administration, foreign policy priorities are usually...more

Cross-Border Investigations Update - November 2017

This issue of Skadden’s semiannual Cross-Border Investigations Update takes a close look at recent cases, regulatory activity and other key developments, including new U.K. reporting obligations for sanctions violations,...more

Red Notice Newsletter - November 2017

ANTICORRUPTION DEVELOPMENTS – SBM Offshore N.V. Agrees to Pay $238 Million to Resolve DOJ FCPA Enforcement Action - On November 29, 2017, SBM Offshore N.V. (SBM), a Netherlands based company specializing in the...more

Enhanced Sanctions On Russia’s Energy Sector

by Fox Rothschild LLP on

In consultation with the Department of State and pursuant to Executive Order 13662, the Director of the Office of Foreign Assets Control (“OFAC”) has updated Directive 4, which will expand sanctions on the Russian energy...more

In Directional Shift, US Implements New Restrictions on Cuba

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

U.S. Government Takes Steps Toward Implementation of Sanctions on Russia

by Jones Day on

The United States has taken significant steps toward fully implementing the sanctions imposed on Russia pursuant to the Countering America’s Adversaries Through Sanctions Act of 2017, which codifies and strengthens certain...more

U.S. Sanctions Developments in the Trump Administration

by BakerHostetler on

The Trump Administration has been active on the sanctions front as a means of asserting United States foreign policy and national security interests. Congress has also taken an increasingly active and direct role of late,...more

What If You Are Ineligible For The Offshore Voluntary Disclosure Program? Attorney Proffers versus Quiet Disclosures

by Sanford Millar on

Since the beginning of the current Offshore Voluntary Disclosure Programs (OVDP) in 2009 tens of thousands of U.S. taxpayers have come forward to report previously undisclosed foreign financial accounts. The addition of the...more

November 2017 Update on Significant DOT, FAA and Other Federal Agencies’ Aviation-Related Regulatory Actions

by Cozen O'Connor on

This edition of the Cozen O’Connor Aviation Regulatory Update discusses new restrictions on Cuba travel, DOT’s Small Community Air Service Development Grant Program, new DOT drug testing requirements for safety-sensitive...more

Retrenchment on Cuban Sanctions; The Search for a Middle Ground

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

Making the Case for Requiring Beneficial Ownership Information

by Michael Volkov on

In this era of aggressive enforcement, global companies have to integrate beneficial ownership requirements when conducting due diligence of business associates and when engaging customers....more

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

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Cybersecurity

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