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Category Archives: Economic Sanctions

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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

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

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 Amends Sudanese Sanction Regulations

Posted in Economic Sanctions, Export Controls
The Office of Foreign Asset Controls (OFAC) has announced that it is issuing a general license for activities prohibited by the Sudanese Sanctions Regulations.  Effectively, that will make the sanctions’ prohibitions inoperative going forward, even as the Sudanese Sanctions Regulations themselves remain in place.  OFAC’s new rules, which become effective today, authorize all transactions that… Continue Reading

The Trump Administration and Sanctions

Posted in Economic Sanctions
During his presidential campaign, President-Elect Donald Trump made few concrete statements regarding sanctions policies. However, it is possible to identify some areas where things might change significantly. Iran: President-Elect Trump has said that he would immediately scrap the Joint Comprehensive Plan of Action (JCPOA) with Iran. The JCPOA has been described as a political commitment… Continue Reading

The Outlook For Sanctions and Export Controls in the Next Administration

Posted in Economic Sanctions, Export Controls
With the presidential election fast approaching, businesses may be wondering what the next administration is likely to do with respect to sanctions and export controls. If Secretary Clinton is elected, the most likely path is a continuation in general of the current policies. If Donald Trump is elected, the prospects are much less clear. And… 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

OFAC Facilitates Authorized Exports and Reexports to Cuba

Posted in Economic Sanctions
On January 27, 2016, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced new amendments to the Cuban Assets Control Regulations (CACR), further liberalizing U.S. trade relations with Cuba. Among these amendments include easing restrictions on the payment and financing terms for authorized exports/reexports to Cuba. Specifically, prior to the issuance of OFAC’s… 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

OFAC Publishes its Much-Anticipated Cyber-Related Sanctions Regulations (Here’s Looking at You, China)

Posted in Economic Sanctions
December 31, 2015: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) has published its Cyber-Related Sanctions Regulations, 31 C.F.R. Part 578. These regulations implement the President’s April 2015 Executive Order (E.O.) 13694, which authorizes the imposition of broad economic sanctions on individuals and entities that are deemed responsible for “malicious cyber-enabled activities,”… 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

The National Emergency Related to Transnational Criminal Organizations Extended Another Year

Posted in Economic Sanctions
On July 21, 2015, President Obama announced a one year extension of the national emergency declared in Executive Order 13581 (July 24, 2011), with respect to transnational criminal organizations (TCOs) as a means to address the “unusual and extraordinary threat to the national security, foreign policy, and economy of the United States constituted by 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

Schlumberger Fine Emphasizes Need to Insulate U.S. Persons from Activities Involving Sanctioned Countries

Posted in Compliance, Economic Sanctions
Schlumberger Oilfield Holdings, the world’s largest oil field services company, has pleaded guilty to one count of conspiring to violate U.S. economic sanctions against Iran and Sudan. As part of its plea arrangement, Schlumberger has agreed to pay a fine of $232.7 million, and three years of corporate probation. The plea agreement concludes an investigation… Continue Reading

Commerzbank Fined $1.45 Billion For Sanctions And Money Laundering Violations

Posted in Anti-Money Laundering, Compliance, Economic Sanctions, National Security
Commerzbank AG, the second-largest bank in Germany, is the latest in a series of foreign banks to be fined hundreds of millions of dollars for violations of U.S. sanctions and anti-money laundering (AML) laws. Commerzbank and its New York branch have agreed to pay fines and forfeitures totaling $1.45 billion, including $259 million imposed by… Continue Reading

New Sanctions May Make Business With Venezuela More Complicated

Posted in Compliance, Economic Sanctions, Export Controls, Trade Policy
On March 9, 2015, President Obama issued a new Executive Order instructing the freezing of the assets and the denial of entry into the United States of seven officials of the Venezuelan government. U.S. persons, including U.S. citizens, permanent residents, and companies, are prohibited from engaging in any transactions with the designated officials, and must… Continue Reading

ITC Invites Companies to Participate in Study on Effects of U.S. Restrictions on Trade With and Travel to Cuba

Posted in Economic Sanctions, Trade Remedies
On January 30, 2015, the U.S. International Trade Commission (ITC), an independent, nonpartisan, fact-finding federal agency, launched an investigation to examine the economic effects on exports of U.S. goods and services on trade with and travel to Cuba.  This investigation is in direct response to a request received by the U.S. Senate Committee on Finance… Continue Reading

Epsilon Files Suit in Rare Challenge to OFAC Penalty Assessment

Posted in Economic Sanctions
The Office of Foreign Assets Control (OFAC) is facing a rare judicial challenge to its authority to impose penalties for violations of U.S. sanctions programs.  The plaintiff, Epsilon Electronics, Inc. (“Epsilon”), is a family-owned California wholesaler of automotive sound and video systems.  Last summer, OFAC hit the company with a civil penalty of more than… Continue Reading

OFAC Amends Sudanese Sanctions Regulations on Personal Communications

Posted in Economic Sanctions, Export Controls
Effective February 18, 2015, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) published a series of amendments to its Sudanese Sanctions Regulations (SSR), 31 C.F.R. Part 538, permitting the export or reexport of certain services, software, and hardware incident to personal communications to or in Sudan.  These amendments were issued in conjunction… Continue Reading