News & Analysis as of

Corporate Counsel Cuba

Foley Hoag LLP

Lessons from the First Four OFAC Sanctions Enforcement Actions under the Second Trump Administration

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Key Takeaways: - After a 5-month pause, OFAC recently announced four sanctions enforcement actions, making clear it is rigorously enforcing sanctions violations across a wide range of programs (including Russia, Iran,...more

Seyfarth Shaw LLP

CHNV Fallout: USCIS Issues Compliance Guidance for Employers

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On June 20, 2025, U.S. Citizenship and Immigration Services (USCIS) issued updated guidance to E-Verify employers regarding the revocation of Employment Authorization Documents (EADs) for individuals who entered under the...more

Goodwin

DOJ’s Data Export Rule Is In Force April 8: What You Need to Do

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On April 8, 2025, a sweeping rule issued by the US Department of Justice (DOJ) will take effect. The rule imposes restrictions—and in some cases, outright prohibitions—on US companies in connection with certain types of data...more

Morrison & Foerster LLP

OFAC Extends Recordkeeping Requirements from Five to 10 Years; Issues Paperwork Reduction Act Request for Comments

On September 11, 2024, OFAC announced its Interim Final Rule to Extend Recordkeeping Requirements from Five to 10 Years. The Interim Final Rule (IFR) was published in the Federal Register on September 13, 2024. Public...more

Holland & Knight LLP

Biden Administration Eases Some Trump-Era Cuba Restrictions

Holland & Knight LLP on

The U.S. Department of State announced on May 16, 2022, a series of measures aimed at supporting the Cuban people and independent Cuban entrepreneurs and loosening Trump-era restrictions that largely isolated the island and...more

Latham & Watkins LLP

Top EU Court Clarifies Anti-US Sanctions “Blocking Statute”

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The court explains how the controversial EU law operates to bar EU persons from complying with US sanctions on Iran and Cuba. On 21 December 2021, the Court of Justice of the European Union (CJEU) released its long-awaited...more

The Volkov Law Group

OFAC Settles with Generali Global Assistance, Inc. for $5.8 Million for Violations of Cuban Sanctions

The Volkov Law Group on

OFAC continues to chalk up enforcement actions.  For the year, even with the pandemic slow down, OFAC has reached 13 settlement agreements totaling $18.6 million in penalties....more

Foley Hoag LLP - White Collar Law &...

White Collar Year in Preview: Sanctions/Export Controls Trends in 2020

This is the sixth in our start-of-year series examining important trends in white collar law and investigations in the coming year. Our previous entry discussed enforcement by the Massachusetts Attorney General’s Office in...more

The Volkov Law Group

General Electric Pays OFAC $2.7 Million for Violations of Cuba Sanctions Program

The Volkov Law Group on

OFAC’s aggressive enforcement program continues to bear fruit.  The latest settlement involved GE and three of its subsidiaries, which agreed to pay $2.7 million for 289 alleged violations of the Cuba Sanctions Program. So...more

The Volkov Law Group

U.S. Entities Engaged in M&A Transactions Beware; OFAC Highlights the “Unique Sanctions Risks” Posed by Foreign Acquisitions

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On June 13, 2019, OFAC announced a settlement with Expedia Group, Inc. for violations of the Cuban Assets Control Regulations (“CACR”).  (Available here).  Expedia’s foreign subsidiaries assisted more than 2,200 individuals...more

Jones Day

Trump Administration Imposes Further Sanctions on Venezuela, Nicaragua and Cuba; Opens Helms-Burton Act Floodgate

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The Situation: On April 17, 2019, the Trump Administration announced additional sanctions targeting the so-called "troika of tyranny" – Venezuela and its key regional allies, Nicaragua and Cuba. These sanctions notably...more

Stinson LLP

United States to Allow U.S. Nationals to Sue Companies Alleged to be Trafficking in Property Confiscated by the Cuban Government

Stinson LLP on

Twenty-three years after Title III of the Helms-Burton Act was enacted and immediately "shelved" by President Clinton, the United States government is reportedly on the verge of permitting U.S. nationals to sue companies that...more

The Volkov Law Group

AppliChem Pays OFAC $5.5 Million for Cuba Sanctions Violations

The Volkov Law Group on

OFAC continues to pile up enforcement actions for sanctions violations. In yet another example of a failure of companies to address compliance, to follow up on compliance and to ensure ultimate compliance, AppliChem...more

Baker Donelson

Cuba Sanctions Guidance: November 2017 Update

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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

Baker Donelson

OFAC Fines American Honda for Foreign Subsidiary’s Business with Cuba

Baker Donelson on

American Honda Finance Corporation (American Honda) has settled with the Office of Foreign Assets Control (OFAC) over potential civil liability for 13 violations of the Cuban Assets Control Regulations (CACR), which that...more

Sheppard Mullin Richter & Hampton LLP

Our Armchair Santería on Cuba Policy: What Will President Trump do on Cuba?

According to reports published this week, the Trump Administration is preparing to release the results of its policy review on Cuba in the “coming weeks.” We don’t have a crystal ball (or a leaking insider). But we continue...more

Pillsbury - Global Trade & Sanctions Law

U.S. Government Continues to Create New Opportunities for Trade with Cuba

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

Foster Garvey PC

A Reality Check for Travel to Cuba in 2016

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With news of the resumption of commercial aviation flights to Cuba, and other changes in the Cuba embargo accomplished through Presidential executive order, it would appear at first blush that the time is ripe to travel to...more

Pillsbury - Global Trade & Sanctions Law

OFAC Provides Helpful New Guidance for Cuba

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

Bracewell LLP

Improved U.S. - Cuba Relations Create Potential FCPA Risks for U.S. Companies Looking to Do Business There

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The normalization of relations between the United States and Cuba offers potential lucrative business opportunities for companies that are prepared to meet Cuba’s unique corruption risks. On December 17, 2014, President...more

Thomas Fox - Compliance Evangelist

Doing Business in Cuba Under the FCPA – Part II

Today, I continue my exploration of doing business in Cuba from the Foreign Corrupt Practices Act (FCPA) perspective. Yesterday, I made clear that anyone you do business with in Cuba is going to be a foreign official under...more

Thomas Fox - Compliance Evangelist

Doing Business in Cuba Under the FCPA – Part I

I am back from a week of cultural and professional exchange in Cuba. It had been a lifelong dream of mine to go to Cuba and I hopped on the first trip I could enroll in after the travel for cultural exchanges were opened up...more

Bryan Cave Leighton Paisner

Easy Come, Easy Go: Latest Developments in US Sanctions

Making regular updates to policies and procedures related to international trade compliance has always been an important aspect of ensuring their effectiveness, and particularly in light of the myriad changes to various U.S....more

Williams Mullen

Key Export Compliance Issues For 2016

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The following are a number of important strategic issues to be considered in the export compliance area for the new year. 1. Recent Country Amendments – New Obligations and New Opportunities. There have been export...more

McDermott Will & Emery

US Treasury and Commerce Departments Announce New Changes to Cuba Regulations

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On January 25, 2016, the US Treasury Department’s Office of Foreign Assets Control (OFAC) and the US Commerce Department's Bureau of Industry and Security (BIS) announced new changes to existing US sanctions on Cuba,...more

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