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
On 14 July, the same day the president signed into law the Hong Kong Autonomy Act (the act), President Trump issued the Executive Order on Hong Kong Normalization (the EO) directing federal agencies to impose a range of trade...more
On 27 February 2020, the Office of Foreign Assets Controls (OFAC) issued General License (GL) 8 authorizing certain humanitarian trade transactions involving the Central Bank of Iran (CBI) that are otherwise prohibited under...more
3/6/2020
/ Banks ,
Commodities ,
Economic Sanctions ,
Food Supply ,
Foreign Relations ,
General Licenses ,
Global Terrorism Sanctions Regulations (GTSR) ,
Humanitarian Assistance ,
Iran ,
Iran Sanctions ,
ITSR ,
Medical Devices ,
Office of Foreign Assets Control (OFAC) ,
Regulatory Requirements ,
Reporting Requirements ,
SDN List ,
Securities and Exchange Commission (SEC) ,
Switzerland ,
Trade Agreements
On 10 January 2020, in response to missile attacks by the Iranian military targeting two U.S. bases in Iraq, the United States Department of the Treasury, Office of Foreign Assets Control (OFAC) designated a number of senior...more
1/14/2020
/ Blocked Person ,
Construction Project ,
Economic Sanctions ,
Executive Orders ,
Foreign Policy ,
Foreign Relations ,
Goods or Services ,
Iran ,
Iran Sanctions ,
Manufacturers ,
Mining ,
Office of Foreign Assets Control (OFAC) ,
Prohibited Transactions ,
SDN List ,
Textiles ,
Trump Administration
On 13 December 2019 the U.S. Department of Justice's (DOJ) National Security Division (NSD) announced the release of its long-anticipated and updated Export Control and Sanction Enforcement Policy for Business Organizations...more
12/19/2019
/ Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Authority ,
Export Controls ,
FCPA Guidance ,
National Security ,
Policy Statement ,
Sanction Violations ,
Self-Reporting ,
Trade Relations ,
Willful Misconduct
On 5 November 2019 the Office of Foreign Assets Control (OFAC) issued two new general licenses authorizing certain transactions involving the government of Venezuela (GOV) and certain individuals affiliated with the GOV,...more
On 14 October, President Donald Trump issued Executive Order 13894, Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation in Syria (EO).
...more
10/18/2019
/ Blocked Person ,
Economic Sanctions ,
Executive Orders ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Syria ,
Trump Administration ,
Turkey ,
Unauthorized Transactions
On 7 October 2019 the U.S. Department of Commerce's Bureau of Industry and Security (BIS) expanded the Entity List, restricting certain transactions with 28 Chinese entities.
...more
10/16/2019
/ Artificial Intelligence ,
Bureau of Industry and Security (BIS) ,
China ,
Doing Business ,
ECCNs ,
Economic Sanctions ,
Educational Institutions ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Foreign Entities ,
Human Rights ,
Research and Development ,
Surveillance ,
Universities
On 4 September 2019 the U.S. State Department issued "Draft 'U.S. Government Guidance for the Export of Hardware, Software and Technology with Surveillance Capabilities and/or parts/know-how'" (draft guidance).
...more
9/12/2019
/ Artificial Intelligence ,
Best Practices ,
Big Data ,
Comment Period ,
Compliance Management Systems ,
Draft Guidance ,
Drones ,
Due Diligence ,
Economic Sanctions ,
Export Controls ,
Exports ,
Facial Recognition Technology ,
Human Rights ,
Policies and Procedures ,
Social Media ,
Software Developers ,
Spyware ,
Surveillance ,
Telecommunications ,
Trump Administration ,
US State Departments
On 2 August the United States announced that it will impose a second round of sanctions on Russia pursuant to the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (CBW Act) (22 U.S.C. § 5601 et...more
On 5 August 2019 the Trump administration issued Executive Order 13884 (the executive order) imposing sweeping sanctions against the government of Venezuela, including its agencies and instrumentalities as well as any...more
On 20 June 2019 the Department of Treasury's Office of Foreign Assets Control (OFAC) issued a final interim rule (effective on 21 June 2019) amending its reporting, procedures, and penalties regulations, 31 Code of Federal...more
7/26/2019
/ Confidential Information ,
Disclosure Requirements ,
Economic Sanctions ,
Factoring Transactions ,
FOIA ,
Food Marketing Institute v Argus Leader Media ,
Interim Rule ,
License Applications ,
Office of Foreign Assets Control (OFAC) ,
Recordkeeping Requirements ,
Regulatory Oversight ,
Regulatory Requirements ,
Reporting Requirements
On 2 May 2019, the U.S. Treasury's Office of Foreign Assets Control ("OFAC"), the agency responsible for enforcing economic sanctions, published "A Framework for OFAC Compliance Commitments" (the "Framework") which outlines...more
7/3/2019
/ Cooperative Compliance Regime ,
Economic Sanctions ,
Failure to Comply ,
Foreign Policy ,
Foreign Relations ,
Framework Agreement ,
Fund Managers ,
Internal Controls ,
Investment Funds ,
Investment Management ,
Office of Foreign Assets Control (OFAC) ,
Private Equity ,
Risk Assessment ,
Sanction Violations
On 2 May 2019 the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) issued "A Framework for OFAC Compliance Commitments" (the framework), which outlines five components OFAC considers to be essential...more
OFAC has announced a Finding of Violation –and not a penalty–against State Street Bank and Trust Co. (SSBT) for processing 45 pension payments totaling under $12,000 on behalf of a pension plan participant who was a US...more
On 28 January 2019, the Department of Treasury’s Office of Foreign Assets Control (OFAC) designated Petróleos de Venezuela, S.A. (PdVSA) as a Specially Designated National (SDN) for operating in the oil sector of the...more
On 19 December 2018, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) submitted a notification to Congress that it plans to terminate sanctions on three major companies originally designated for...more
On 5 November 2018 the United States re-imposed the remaining nuclear-related secondary sanctions administered by the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) against Iran that previously had...more
11/8/2018
/ Economic Sanctions ,
Financial Institutions ,
Foreign Policy ,
Iran ,
Iran Sanctions ,
ITSR ,
Joint Comprehensive Plan of Action (JCPOA) ,
Nuclear Weapons ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
SDN List ,
Shipping Cargo ,
Trump Administration
The past two weeks have entailed a flurry of sanctions developments related to Russia, including the issuance of a new executive order, and the designation of a number of entities by the U.S. Department of the Treasury's...more
The United States has begun re-imposing nuclear-related sanctions with respect to Iran in connection with the expiration of the 90-day wind-down period announced alongside the United States' 8 May 2018 withdrawal from the...more
8/13/2018
/ Economic Sanctions ,
Energy Sector ,
Financial Institutions ,
Foreign Investment ,
Foreign Policy ,
Foreign Relations ,
Insurance Industry ,
Iran ,
Iran Sanctions ,
ITSR ,
Nuclear Weapons ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Shipping
On 8 August, the U.S. Department of State announced that new sanctions would be imposed on Russia pursuant to the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (CBW Act). The sanctions relate to...more
In furtherance of President Trump’s 8 May 2018 announcement that the United States would withdraw from the Iran nuclear deal—the Joint Comprehensive Plan of Action (JCPOA)—on 27 June 2018, the U.S. Department of Treasury’s...more
Today, the Trump Administration designated multiple Russian targets, including several wealthy individuals and their companies, as Specially Designated Nationals (SDNs). These designations of major companies represent the...more
On Monday, 29 January, the U.S. Treasury Department submitted an unclassified report to Congress concerning significant senior political figures and oligarchs in the Russian Federation and Russian parastatal entities.
...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