By Jack Shane, Daniel Pickard, Lori Scheetz and Usha Neelakantan on Posted in Economic SanctionsToday, 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
By Usha Neelakantan on Posted in Economic SanctionsOn 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
By Usha Neelakantan on Posted in Economic SanctionsAs 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
By Tessa Capeloto on Posted in Export ControlsOn March 15, 2016, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced changes to its Cuban Assets Control Regulations (CACR), which aim to improve the lives of the Cuban people and encourage more active engagement between the United States and Cuba, while at the same time limiting any benefits to… Continue Reading
By Tessa Capeloto on Posted in Economic SanctionsOn 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
By Usha Neelakantan on Posted in Economic SanctionsFollowing 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
By Usha Neelakantan on Posted in Economic SanctionsAs 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
By Alexandra E. Landis and D. Scott Nance on Posted in Economic SanctionsDecember 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
By Usha Neelakantan and D. Scott Nance on Posted in Economic SanctionsOn 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
By Tessa Capeloto on Posted in Economic SanctionsOn 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
By Usha Neelakantan on Posted in Economic SanctionsFollowing 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
By D. Scott Nance on Posted in Compliance,Economic SanctionsSchlumberger 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
By D. Scott Nance on Posted in Anti-Money Laundering,Compliance,Economic Sanctions,National SecurityCommerzbank 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
By D. Scott Nance on Posted in Compliance,Economic Sanctions,Export Controls,Trade PolicyOn 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
By Tessa Capeloto on Posted in Economic Sanctions,Trade RemediesOn 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
By Usha Neelakantan on Posted in Economic SanctionsThe 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
By Tessa Capeloto on Posted in Economic Sanctions,Export ControlsEffective 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
By Usha Neelakantan on Posted in Economic SanctionsOn 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
By Tessa Capeloto on Posted in Export ControlsOn January 16, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced the issuance of the agency’s eagerly anticipated amendments to the Cuban Assets Control Regulations (CACR), which are designed “to increase people-to-people contact, support civil society in Cuba, enhance the free flow of information to, from, and among the Cuban people, and… Continue Reading
By Tessa Capeloto on Posted in Economic Sanctions,National SecurityTwo 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
By Usha Neelakantan on Posted in Economic SanctionsOn 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
