On June 16, 2017, President Trump issued a National Security Presidential Memorandum on Strengthening the Policy of the United States Toward Cuba, which begins a process to alter some aspects of U.S. policy towards Cuba, but...more
On June 15, 2017, the Senate passed the Countering Iran’s Destabilizing Activities Act of 2017 (S.722) by a vote of 98-2. Included with the bill is a significant Russia sanctions amendment, the Countering Russian Influence...more
On 16 March 2017, the European Parliament approved a draft EU regulation intended to ensure that trade in certain minerals and metals from high-risk or warn-torn areas does not fund conflict and human rights abuses. The...more
Policy makers in Europe continue to explore responses to the Panama Papers revelations and recent terrorist attacks. On 28 February, European law makers approved important amendments to the EU’s Anti-Money Laundering (AML)...more
On February 8, 2017, the U.S. Department of Justice (DOJ) released a list of important topics and sample questions that the Criminal Division’s Fraud Section has frequently found relevant in evaluating the adequacy of a...more
3/10/2017
/ Compliance ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Ethics ,
Federal Pilot Programs ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Internal Reporting ,
Policies and Procedures ,
Risk Assessment ,
Tone At The Top ,
Yates Memorandum
OFAC has issued a new General License to address problems raised by the sanctioning of the Federal Security Services (FSB). This adjustment serves to authorize permits by the FSB needed for certain commercial transactions...more
Effective January 17, 2017, a new general license authorizes a broad range of activities previously prohibited under the Sudanese Sanctions Regulations (SSR), including most transactions with individuals and entities in Sudan...more
On December 15, 2016, the Office of Foreign Assets Control (OFAC) provided updated guidance on what companies can expect in the event of the “snapback” of sanctions under the Joint Comprehensive Plan of Action (JCPOA). ...more
On November 30, 2016, the United Nations Security Council (UNSC) passed a unanimous resolution strengthening sanctions against North Korea. The Resolution comes in response to the conduct of the latest round of nuclear tests...more
Donald Trump’s victory in the 2016 Presidential election put the Republican Party in charge of the White House and Congress for the first time in a decade. President-elect Trump ran as an anti-establishment candidate who...more
In a shock to investors and political analysts around the world, Donald J. Trump won the 2016 Presidential election, putting the Republican Party in charge of the White House and Congress for the first time in a decade. Even...more
Both the U.S. Treasury’s Office of Foreign Assets Control (OFAC) and the Department of Commerce’s Bureau of Industry and Security (BIS) have announced new amendments to the Cuban Assets Control Regulations (CACR) and Export...more
On September 15, 2016, President Obama announced that U.S. economic sanctions on Myanmar (also known as Burma) would end, but the announcement left many questions as to what would change and what sanctions might remain. On...more
On September 1, 2016 new rules previously published by the U.S. Department of Commerce, Bureau of Industry and Security (BIS) and the U.S. Department of State, Directorate of Defense Trade Controls (DDTC) will become...more
On September 1, 2016 new rules previously published by the U.S. Department of Commerce, Bureau of Industry and Security (BIS)1 and the U.S. Department of State, Directorate of Defense Trade Controls (DDTC)2 will become...more
9/2/2016
/ Bureau of Industry and Security (BIS) ,
Cloud Computing ,
Corporate Counsel ,
Data Security ,
Digital Data ,
Directorate of Defense Trade Controls (DDTC) ,
Encryption ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
ITAR ,
Modification ,
Passwords
On May 23, 2016, during President Obama’s visit to Ho Chi Minh City, the United States announced the termination its long-standing arms embargo policy for Vietnam. Exports of defense articles and defense services to Vietnam...more
On May 11, 2016, the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Department of Treasury, published its final rule addressing Customer Due Diligence Requirements for Financial Institutions (CDD Rule)....more
The Office of Foreign Assets Control (OFAC) updated its FAQs for Cuba on April 21, 2016 with substantive guidance that addresses U-turn transactions, export policy, insurance, educational and humanitarian activities and...more
In advance of President Obama’s highly publicized trip to Cuba, the Administration took additional steps to ease restrictions on trade and travel with Cuba. These changes to the Cuban Assets Control Regulations (CACR) and...more
4/12/2016
/ Banking Sector ,
Barack Obama ,
Cuba ,
Cuban Assets Control Regulations (CACR) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Office of Foreign Assets Control (OFAC) ,
Physical Presence Test ,
Shipping ,
Travel
The United Nations and United States recently took significant new steps to expand sanctions on North Korea, with implications for international banking; shipping and port activities; air transport; energy and mining sectors;...more
In advance of President Obama’s highly publicized trip to Cuba, the Administration took additional steps to ease restrictions on trade and travel with Cuba. These changes to the Cuban Assets Control Regulations (CACR) and...more
The United Nations and United States recently took significant new steps to expand sanctions on North Korea, with implications for international banking; shipping and port activities; air transport; energy and mining sectors;...more
4/4/2016
/ Censorship ,
Economic Sanctions ,
Embargo ,
Executive Orders ,
Human Rights ,
International Finance ,
North Korea ,
Oil & Gas ,
Shipping ,
U.S. Treasury ,
UN Security Council
There has been much discussion of U.S. and EU sanctions changes following Implementation Day under the Joint Comprehensive Plan of Action (“JCPOA”), but a number of countries had imposed sanctions for Iran and it is worth...more
2/29/2016
/ Australia ,
Canada ,
Export Controls ,
Exports ,
Financial Institutions ,
Imports ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Nuclear Power ,
SDN List ,
United Nations
The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking on August 25, 2015 which, among other things, would add SEC-registered investment advisers to the “financial...more
9/2/2015
/ Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Currency Transaction Reports (CTR) ,
Financial Institutions ,
FinCEN ,
Investment Adviser ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
Suspicious Activity Reports (SARs) ,
U.S. Treasury
Given London’s role in international business and finance, the UK Bribery Act 2010 promised to form a potential strong counterpart to the U.S. Foreign Corrupt Practices Act (FCPA). Now, the UK government is taking steps which...more