In a move that may honestly mean more to America than to Cuba, the White House has announced that President Obama will remove Cuba from the U.S. list of “State Sponsors of Terrorism.” The U.S. Department of State has listed...more
Iran and the Western powers have agreed to agree again. On April 2, 2015, the so-called P5+1 (the United States, the UK, China, France, and Russia) along with the EU, have joined Iran in announcing that they have reached a...more
One aspect of the dramatic shift in U.S. policy toward Cuba that has not been widely reported is a relaxation of the old rule prohibiting imports of most Cuban goods and services. Under the new rules, if your Cuban supplier...more
On January 15, 2015, the Department of Treasury’s Office of Foreign Assets Control (OFAC) amended the Cuban Assets Control Regulations to implement changes in U.S. policy toward Cuba announced by President Obama on December...more
1/23/2015
/ Amended Legislation ,
Banking Sector ,
Barack Obama ,
Cuba ,
Cuban Assets Control Regulations (CACR) ,
Embargo ,
Executive Orders ,
Export Controls ,
Exports ,
Imports ,
Office of Foreign Assets Control (OFAC) ,
Sanctions ,
Telecommunications ,
Travel Permits ,
U.S. Commerce Department ,
U.S. Treasury
New regulations on Cuba enter into force today, only 29 days after President Obama promised them. The liberalized provisions focus on support for private sector actors in Cuba. As we described here, the President announced on...more
Today, the Department of Treasury’s Office of Foreign Assets Control (OFAC) amended the Cuban Assets Control Regulations to implement changes in U.S. policy toward Cuba announced by President Obama on December 17, 2014....more
U.S. economic sanctions, by their nature, often change without warning. Since sanctions reflect U.S. foreign and national security policy, they must evolve rapidly with world events. Often, it seems that when one door is...more
Today President Barack Obama made a stunning speech announcing steps the United States will take to reduce U.S. sanctions against Cuba. The announcement followed the release of two U.S. citizens held by the Cuban government....more
Every time there is a new round of reforms under the President’s Export Control Reform initiative, we hear the same advice:
- Controls on certain items are eliminated or reduced (which creates new opportunities for...more
12/8/2014
OFAC Expands the 50 Percent Rule -
Last month, the Department of Treasury’s Office of Foreign Assets Control (OFAC) released new guidance related to entities owned or controlled by persons designated as a Specially...more
In a stunning ruling issued on July 15, 2014, the U.S. Court of Appeals for the D.C. Circuit held that review by the Committee on Foreign Investment in the United States (“CFIUS”) and the subsequent unwinding of the...more
A red sky at morning is the traditional harbinger of ill weather. From our vantage point in Brussels, we’ve scanned the horizon for signs of the future of anti-bribery enforcement activity in Europe. We’ve identified four...more
There’s no end in sight for the turmoil in Ukraine. And there’s no end in sight for international sanctions against Russia for causing that turmoil. As sanctions escalate, so will the collateral damage. New sanctions...more
In response to Russia’s military presence in the Crimean region of Ukraine, President Obama issued an Executive Order (“EO”) on March 6, 2014, authorizing the blocking of property of individuals and entities involved in the...more
The U.S. District Court for the Southern District of New York has held that the whistleblower protection provisions of the Dodd-Frank Act do not apply outside the United States, even where the employee alleged he was...more
Since Hassan Rouhani’s election to the Iranian presidency, some U.S. leaders have expressed interest in diplomatic talks with Iran. It is currently unclear whether any such talks will ever occur, or on what terms. In the...more
This fall, the U.S. Government will finish considering public comments on its draft revision of U.S. Munitions List Category XV, which covers “Spacecraft Systems and Related Articles.” By the end of 2013 (unless delayed by...more
One FCPA compliance topic we are often asked about by clients is how government investigations start. The U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) have developed a number of mechanisms...more
Since 2011, President Barack Obama’s administration has actively pursued export control reform designed to reduce the regulatory burdens on U.S. companies and enhance U.S. national security (as reported here). On March 7,...more
The U.S. Government has taken yet another step to counter the threat of Iran-sponsored terrorism, this time focusing on Iran’s direct activities in the Western Hemisphere. On December 28, 2012, President Barack Obama signed...more
As the new year brings in a new term for the Obama Administration, the pace of Iran sanctions shows no sign of slowing. As we reported in October and November, Washington’s commitment to denying Iran the ability to advance...more
2/15/2013
/ Coal ,
FFI ,
IFCPA ,
Iran Sanctions ,
Metals ,
NDAA ,
Office of Foreign Assets Control (OFAC) ,
Reinsurance ,
SDN List ,
Shipbuilding ,
Shipping ,
Software ,
Underwriting
Much has been said about what is missing from the new FCPA Resource Guide (the Guide) published by the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC). Here, we consider instead the areas in...more
As we reported last month, the Obama administration continues to display a commitment to increasingly tough sanctions against Iran and its trading partners. Over the past few weeks, the U.S. Department of the Treasury, Office...more
11/20/2012