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Category Archives: Economic Sanctions

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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

OFAC Eases Restrictions on Travel to Cuba

Posted in Economic Sanctions
On January 16, 2015, the U.S. Department of the Treasury’s Office of Foreign Assets Control significantly eased restrictions on travel to and from Cuba, as well as transactions normally incident to such travel. While tourist travel to Cuba remains prohibited, travel and transactions for a variety of other purposes will now be permitted: Family visits:  In… Continue Reading

Jail Time Handed Down for Zimbabwe Lobbyists

Posted in Economic Sanctions, National Security
Two individuals were recently charged and sentenced for violating U.S. sanctions against Zimbabwe and the Foreign Agents Registration Act (FARA), underscoring the potential legal risks associated with engaging in business activities with foreign entities that are subject to U.S. economic sanctions.  It also highlights the dangers of failing to register under the little-known FARA. On Tuesday,… Continue Reading

OFAC and Commerce Amend Their Cuba Regulations to Open Up Trade and Investment with Cuba

Posted in BIS, Economic Sanctions, Export Controls
Today, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced the issuance of their eagerly awaited amendments to the Cuban Assets Control Regulations (CACR) and the Export Administration Regulations (EAR), respectively.  These amendments implement the President’s policy to significantly ease restrictions… Continue Reading

OFAC Expands North Korean Sanctions

Posted in Economic Sanctions
On January 2, 2015, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) blocked the property and interests in property of several North Korean entities and representatives operating outside North Korea.  The designations followed the issuance of an Executive Order that authorized sanctions against the government of North Korea and the Worker’s… Continue Reading

Identifying UBOs: The Conflict Between FINCEN and OFAC

Posted in Anti-Money Laundering, Compliance, Economic Sanctions
Identifying who the hidden owners of an entity may be is a key step in combatting money laundering and terrorist financing and complying with U.S. sanctionslaws. For banks in particular, this means identifying the ultimate beneficial owners (UBOs) of customers who are legal entities. Typically, banks will try to identify everyone holding some specified percentage… Continue Reading

Foreign Exchange Trading: The Need For Internal Controls

Posted in Anti-Money Laundering, Economic Sanctions
On November 12, 2013, the Commodity Futures Trading Commission (CFTC) announced that it had imposed fines totaling $1.4 billion on five major international banks in connection with the alleged manipulation of foreign exchange benchmark rates. In each case, the CFTC asserted that individual traders within the banks had colluded to move benchmark foreign exchange rates,… Continue Reading