American Trade & Manufacturing Blog

Usha Neelakantan

Usha Neelakantan

Usha Neelakantan represents clients in a range of international trade matters, including antidumping and countervailing duty investigations, export controls, and economic sanctions compliance programs. She also provides guidance on national security issues, including regulations promulgated by the Committee on Foreign Investment in the United States (CFIUS).

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OFAC Sanctions Petroleos de Venezuela, S.A. (PdVSA)

Posted in Economic Sanctions
In light of the political crisis in Venezuela and the U.S. government’s support for the self-declared Interim President, Juan Guadió, on January 28, 2019, the Office of Foreign Assets Control (OFAC) added Petróleos de Venezuela, S.A. (PdVSA), Venezuela’s state-owned oil and gas company, to its list of Specially Designated Nationals and Blocked Persons. As a result, U.S. persons… Continue Reading

The Crisis in Venezuela – New Sanctions Forthcoming?

Posted in Economic Sanctions, Export Controls
On January 23, 2019, the leader of Venezuela’s National Assembly, Juan Guaidó, declared himself the acting President of Venezuela and announced he would assume the powers of the Venezuelan executive branch until new national elections are held. The move was a direct challenge to Venezuela’s sitting president, Nicolás Maduro, who was reelected to a second… Continue Reading

CFIUS Reform Legislation Signed into Law – Important Changes Become Effective Immediately

Posted in CFIUS
President Trump signed the Foreign Investment Risk Review Modernization Act (FIRRMA) into law today, August 13, 2018, as part of the National Defense Authorization Act for Fiscal Year 2019 (NDAA). FIRRMA significantly expands the jurisdiction of the Committee on Foreign Investment in the United States (CFIUS) to review transactions that were not previously subject to… Continue Reading

OFAC Revokes JCPOA-Related General Licenses and Issues Wind-Down Authorizations

Posted in Announcements
Following the President’s May 8, 2018 withdrawal from the Joint Comprehensive Plan of Action (JCPOA), today, the Office of Foreign Assets Control (OFAC) revoked General License H (GL H), which authorized U.S.-owned or -controlled foreign entities to engage in business with Iran, and General License I (GL I), which authorized U.S. persons to negotiate and enter into contingent… Continue Reading

House Passes CFIUS Reform Bill

Posted in CFIUS
The U.S. House of Representatives yesterday passed by an overwhelming margin of 400-2 its version of the Foreign Investment Risk Review Modernization Act (FIRRMA). The landmark bipartisan legislation would significantly expand the jurisdiction and operational mandate of the Committee on Foreign Investment in the United States (CFIUS) and reform the CFIUS review process in a… Continue Reading

President Trump Withdraws from Iran Nuclear Deal; U.S. Sanctions to be Re-Imposed

Posted in Economic Sanctions
President Trump today announced the United States’ withdrawal from participation in the Joint Comprehensive Plan of Action (JCPOA), the landmark 2015 agreement that eased sanctions on Iran in exchange for curbs on Iran’s nuclear program. Pursuant to the withdrawal, President Trump has directed his Administration to immediately begin the process of re-imposing sanctions against Iran, targeting the Iranian energy,… Continue Reading

Trump Administration Sanctions Russian Oligarchs and Government Officials

Posted in Economic Sanctions
Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated several Russian individuals and entities, including seven Russian oligarchs and 17 top Russian government officials, pursuant to the Countering America’s Adversaries Through Sanctions Act of 2017 (CAATSA) and Executive Orders related to Ukraine and Syria. The full list of individuals and… Continue Reading

U.S. Trade Representative Announces Safeguard Tariffs on Solar Cell and Module Imports

Posted in Trade Remedies
On Monday, the Trump Administration announced that President Trump had approved the imposition of new tariffs on imports of solar cells and modules, as well as a tariff-rate quota on imports of washing machines. The government will impose a 30% tariff on all imported cells and modules in the first year, which will drop to… Continue Reading

Agencies Amend Cuba Sanctions to Implement President Trump’s June National Security Presidential Memorandum

Posted in BIS, Economic Sanctions, Trade Policy
Last week, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), and the U.S. Department of State took steps to implement restrictions on tourism and trade with Cuba, which were announced by President Trump in June. Consistent with the National Security… Continue Reading

Updated Foreign Agents Registration Act (FARA) Handbook

Posted in Announcements
Wiley Rein has updated our Foreign Agents Registration Act (FARA) Handbook, which reviews the rules that govern whether an entity should register with the FARA Registration Unit of the U.S. Department of Justice, the registration process, the obligations of registered agents, and the penalties that may be imposed for FARA violations. Any person who engages… Continue Reading

Treasury Imposes New Sanctions on Venezuela

Posted in Economic Sanctions
On August 24, 2017, President Trump signed Executive Order 13808 imposing new sanctions against Venezuela largely in response to the political situation in the country, including the “establishment of an illegitimate Constituent Assembly, which has usurped the power of the democratically elected National Assembly and other branches of the Government of Venezuela.”   The new sanctions… Continue Reading

Treasury Department Adds 16 Entities/Individuals to SDN List

Posted in Economic Sanctions
One day after President Trump reluctantly certified that Iran has been complying with the terms of the Joint Comprehensive Plan of Action relating to its nuclear program, the U.S. Treasury Department sanctioned 16 entities and individuals for supporting the Iranian military and Iran’s Islamic Revolutionary Guard Corps.  The designated entities are reported to have assisted… Continue Reading

AIG Settles Potential Violations of U.S. Sanctions Regulations

Posted in Economic Sanctions
On June 26, 2017, the Office of Foreign Assets Control (OFAC) announced a settlement with global insurance giant American International Group, Inc. (AIG) for apparent violations of multiple U.S. sanctions regimes, including the regimes relating to Iran, Sudan, Cuba, and Weapons of Mass Destruction Proliferators.   The apparent violations involved 555 transactions totaling approximately $396,530 in… Continue Reading

Trump Administration Announces Curbs On Travel and Trade With Cuba

Posted in BIS, Economic Sanctions, Trade Policy
President Trump today announced plans to restrict tourism and trade with Cuba, retreating from certain aspects of the Obama Administration’s liberalization of ties with the communist regime. Intended to strictly enforce the statutory ban on tourism to Cuba and to restrict the flow of money to the Cuban military, intelligence, and security services, the new… Continue Reading

Treasury Publishes List of Boycotting Countries

Posted in Compliance
On March 30, 2017, the U.S. Department of the Treasury (Treasury) published its current list of countries that require cooperation with an international boycott. Treasury, along with the U.S. Department of Commerce (Commerce), administers antiboycott laws and associated guidelines that were enacted in response to the Arab League’s boycott of Israel. Treasury’s rules apply to… Continue Reading

Easing Sanctions Against Russia? Congress Says Not So Fast, Mr. President

Posted in Economic Sanctions
Despite early rumors that President Trump would lift the Obama Administration’s economic sanctions against Russia, it might not be so quick or so easy, if Congress has its way.  Two pieces of legislation have been introduced in Congress, the first aimed at inhibiting the President’s ability to ease the current Russian sanctions regime and the… Continue Reading

Trump Administration Imposes Fresh Sanctions on Iran

Posted in Economic Sanctions
On February 3, 2017, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned more than two dozen individuals and entities related to Iran’s ballistic missile program and the Islamic Revolutionary Guard Corps – Qods Force (IRGC-QF).  The move comes amid escalating tensions between the Trump Administration and the Iranian government. The… Continue Reading

OFAC Targets Ukraine/Russia-Related Sanctions Evaders

Posted in Economic Sanctions
As part of its continued efforts to oppose Russia’s conduct in Ukraine and its occupation of Crimea, on September 1, 2016, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated 37 individuals and entities related to the conflict in Ukraine.  The new designations are, in part, intended to address attempts to circumvent… Continue Reading

Wiley Rein Releases In a Nutshell: What You Need to Know About the FCPA in 2015

Posted in FCPA
On February 29, Wiley Rein published its annual Foreign Corrupt Practices Act (FCPA) Year-in-Review article: In a Nutshell: What You Need to Know About the FCPA in 2015.  The article provides statistics on enforcement actions and penalties, an analysis of investigative trends and more, chronicling another busy year in FCPA enforcement.  Some of the points… Continue Reading

OFAC Further Eases Travel Restrictions to Cuba

Posted in Economic Sanctions
Following the United States government’s easing of sanctions against Cuba last year, the Office of Foreign Assets Control (OFAC) loosened travel restrictions for U.S. persons.  At the beginning of last year, OFAC authorized 12 categories of travel (detailed here).  Effective January 27, 2016, OFAC has further eased travel restrictions within certain of those categories. Exportation,… Continue Reading

OFAC Eases Sanctions Against Iran, But Restrictions Remain in Place for U.S. Companies

Posted in Economic Sanctions
As most U.S. companies are aware, on January 16, 2016, “Implementation Day” of the Joint Comprehensive Plan of Action (JCPOA), the United States lifted several prohibitions on doing business with Iran. These include the removal of secondary sanctions against non-U.S. companies and the lifting of restrictions on foreign subsidiaries of U.S. companies doing business with… Continue Reading

Iran Sanctions Relief and Uncertainty Under the JCPOA

Posted in Economic Sanctions
On July 14, 2015, Iran, the United States, the United Kingdom, China, France, Russia, and Germany finalized a Joint Comprehensive Plan of Action (JCPOA) intended to restrict Iran’s nuclear activities in exchange for easing international sanctions against the country.  While the text of the JCPOA provides a relatively detailed framework for the implementation of the… Continue Reading

OFAC Issues Guidance on Travel to and from Cuba

Posted in Economic Sanctions
Following the United States’ recent easing of sanctions against Cuba, the Office of Foreign Assets Control (OFAC) has released additional guidance on travel between the two countries. The guidance is particularly relevant to companies authorized to provide carrier services via aircraft or commercial passenger vessels. According to the guidance, the following individuals may be transported… Continue Reading