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OFAC Guidance on U.S. Dollar Transactions Involving Iran

On October 7, 2016, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) published new guidance clarifying (a) circumstances under which non-U.S. financial institutions (FFIs) may engage in U.S. dollar...more

Is Chinese Investment in the U.S. Film and Entertainment Industry the Next Area of CFIUS Scrutiny?

U.S. lawmakers recently submitted a letter to the Government Accountability Office (GAO) raising concerns about increased Chinese investments in the U.S. film and entertainment industry and questioning whether the Committee...more

Russia Sanctions Update: OFAC, BIS Expand Sanctions Lists

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued new Russia/Ukraine-related sanctions on Thursday, September 1, 2016. This action marks OFAC’s first major expansion of the Specially...more

Cleared for Takeoff: OFAC’s General License J Allows Boeing, Airbus and Other Aircraft to Land in Iran

On July 29, 2016, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) issued a new General License J (GL-J). GL-J authorizes the reexportation of certain civil aircraft on temporary sojourn to Iran,...more

Export Control Reform Offers Revisions to Key Terms, and DDTC Increases Penalty Authority; More Work Remains (Part 1)

On June 3, 2016, the U.S. Department of State, Directorate of Defense Trade Controls (DDTC) and the Department of Commerce, Bureau of Industry and Security (BIS) issued changes to the International Traffic in Arms Regulations...more

Cuba Natural Gas

CNG – Cuba Natural Gas - With the recent shift in U.S. government policy regarding Cuba, is now the time for the energy industry, particularly liquefied natural gas (LNG) project developers, to consider Cuba?...more

Anti-Corruption Summit: Extending Corporate Liability for Economic Crimes?

In a keynote address at the London Anti-Corruption Summit, Prime Minister David Cameron raised the possibility of new U.K. legislation to make corporations liable for “failure to prevent” fraud or money-laundering offenses...more

Cuba on Trend: Chanel Hosts Fashion Show in Havana as Diplomatic and Cultural Relations Continue to Open with Cuba

On May 3, French fashion house Chanel hosted the first international fashion show in Cuba since the 1959 communist revolution. The Resort 2017 show was held open-air in Paseo del Prado, one of the city’s central streets. It...more

OFAC Adopts New Sanctions Targeting Hizballah’s Financial and Logistics Networks

If you only read one thing... - The Hizballah Financial Sanctions Regulations (HFSR) are intended to disrupt Hizballah’s global logistics and financial network by providing a new basis of secondary sanctions...more

OFAC Authorizes Certain Commercial Passenger Aircraft Transactions with Iran

On March 24, 2016, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued General License I authorizing U.S. persons to undertake certain transactions ordinarily incident to the negotiation of, and...more

BIS Grants Temporary Relief for Two ZTE Companies and their Suppliers

In an extraordinary development, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a new rule, effective March 24, 2016, creating a temporary general license for two entities—Zhongxing...more

Obama Administration Further Eases Sanctions in Advance of Cuba Visit

On Wednesday, March 16, 2016, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) implemented amendments to the Cuban...more

U.S. Export Controls Restrictions Imposed on Chinese Telecommunications Giant ZTE

Effective March 8, 2016, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a final rule adding Zhongxing Telecommunications Equipment Corporation (ZTE) of Shenzhen, China, and the following...more

Obama Administration Further Relaxes Sanctions in Support of Cuba Policy

If you read one thing… - Further relaxation of sanctions on Cuba, effective on January 27, 2016, allows U.S. financial institutions to finance authorized exports and reexports to Cuba of items other than...more

What Implementation of the Iran Nuclear Deal Means for Non-U.S. Companies

On January 16, 2016, the International Atomic Energy Agency (IAEA) verified, and U.S. Secretary of State John Kerry confirmed, that Iran had implemented its key nuclear-related measures described in the Joint Comprehensive...more

What Implementation of the Iran Nuclear Deal Means for U.S. Companies and Their Subsidiaries Abroad

If you read one thing... - There are far greater opportunities for U.S. companies with respect to Iran, particularly through foreign subsidiaries and in the commercial aviation sector, however, U.S. persons and...more

Corporate Bribery: Successful Prosecutions in the United Kingdom

In a busy week for the Serious Fraud Office (SFO), the United Kingdom’s antibribery prosecutor, it has announced its first-ever deferred prosecution agreement (DPA) for bribery offences and the first guilty plea under the...more

Corporate Bribery: Successful Prosecutions in the United Kingdom

In a busy week for the Serious Fraud Office (SFO), the United Kingdom’s antibribery prosecutor, it has announced its first-ever deferred prosecution agreement (DPA) for bribery offences and the first guilty plea under the...more

OFAC Expands List of Medical Supplies Eligible for Export to Iran under General License

On November 2, 2015, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) updated the List of Medical Supplies eligible for export or reexport to Iran under the general license set forth at Section...more

US State Department Releases Contingent Waivers of Iran Extraterritorial Sanctions

On October 18, 2015, the day on which the Joint Comprehensive Plan of Action (“JCPOA”) became effective (“Adoption Day”), the U.S. Department of State (“State Department”) issued contingent waivers of certain extraterritorial...more

Obama Administration Further Eases Restrictions to Aid Implementation of Cuba Policy

On Monday, September 21, 2015, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) implemented amendments to the Cuban...more

Russia Sanctions Update

On September 2, 2015, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a final rule amending the Export Administration Regulations (EAR) by adding 29 parties to its Entity List, a...more

U.S. Department of Commerce Places Severe Export Restrictions on Russian Deepwater Oil and Gas Field

On August 7, 2015, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published a final rule adding the Yuzhno-Kirinskoye Field, a Russian oil and gas field located in the Sea of Okhotsk, to its Entity...more

OFAC Releases Crimea Sanctions Advisory

On July 30, 2015, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a Crimea Sanctions Advisory highlighting certain practices that have been used to circumvent or evade U.S. sanctions...more

Sanctions Relief to Expect from the Nuclear Deal with Iran

On July 14, 2015, Iran and the P5+1 countries (China, France, Germany, Russia, the United Kingdom and the United States), with the High Representative of the European Union for Foreign Affairs and Security Policy, finalized...more

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