Tag Archives: OFAC

North Korea Sanctions Continue to Intensify

On September 11, 2017, the UN Security Council unanimously imposed new sanctions on North Korea. The move came only days after Pyongyang launched an underground nuclear test that may have been the detonation of a hydrogen bomb. The American Ambassador to the UN, Nikki Haley, announced the new sanctions by declaring that “today, we are … Continue Reading

In the Chaos of (Trade) War, Where Does Your Company Find Peace?

On July 27, 2017, the U.S. Congress sent to President Trump’s desk a bill that imposes new financial sanctions against Russia, Iran, and North Korea. It appears nearly certain that the president will sign that bill, now called the “Countering America’s Adversaries Through Sanctions Act” (CAATSA). Edit: President Trump signed the bill on August 2, … Continue Reading

Our Cuba Sanctions Predictions: How Did We Do?

In our last post, we made a few cocky predictions about the new Trump Administration’s Cuba policy. We correctly asserted that the President would try to chart a narrow course between the Scylla of conservative Cuban-American expectations for an outright return to the embargo and the Charybdis of U.S. interests (business, strategic, and cultural) in … Continue Reading

A New Sleuth in Britain: The UK Quietly Empowers a Sanctions Enforcement Office

On April 3, 2017, the UK Treasury’s Office of Financial Sanctions Implementation (OFSI) announced new penalties for economic sanctions violations of £1 Million or 50% of the value of the transaction, whichever is higher. As a result, this new detective has a powerful new enforcement tool, and it may be taking notes from the aggressive U.S. … Continue Reading

The Future of Russia Sanctions: The Awkward Edition

On January 10, 2017, Senate Republicans and Democrats introduced bi-partisan legislation called the “Countering Russian Hostilities Act of 2017,” which would impose broad sanctions on Russia. The Act would codify the sanctions President Obama imposed in response to the Russian cyberattack on the United States to influence the 2016 U.S. Presidential election and the Ukraine-related … Continue Reading

The Table Flip: Trump, the Iran Nuclear Deal, and American Business

A President Trump will have authority to reinstate sanctions lifted by the Iran Nuclear Deal as well as revoke certain authorizations provided for business with Iran. Several economic and geopolitical factors may cause Mr. Trump to reconsider or mitigate his approach to the Iran Nuclear Deal. Companies should prepare to respond quickly to any changes. … Continue Reading

Negotiation By Tweet: The Uncertain Future of U.S.-Cuba Relations

After the announcement of Fidel Castro’s death on November 26, 2016, President Barack Obama sent a message to the Cuban people highlighting his administration’s efforts to improve relations between the United States and Cuba. “History will record and judge the enormous impact of this singular figure on the people and world around him…[T]he Cuban people … Continue Reading

Obama’s Not Slowing Down On Cuba: New Steps Forward Open Doors (and Humidors!) for Collaboration

With fewer than 100 days left in office, President Obama is not slowing down on his efforts to normalize relations between the United States and Cuba. Today, several changes to the Cuban Assets Control Regulations (CACR) and Export Administration Regulations (EAR) go into effect. Those changes build on the plan President Obama laid out in … Continue Reading

Those Three Little Words: OFAC’s Subtle Language Shift Could Create Sweeping Change on Iran Investment

Article Highlights: Non-U.S. banks can do business with Iran and continue their relationships with U.S. banks. Non-U.S. companies may use proceeds from Iran transactions more freely, including in the United States. OFAC draws a clearer line with respect to the use of Iran-related funds. After the Iran nuclear agreement, as non-U.S. companies entered into newly-permitted … Continue Reading

Layover in Tehran: United States Authorizes Carriers to Land Civil Aircraft in Iran

On July 29, 2016, the U.S. Treasury Office of Foreign Assets Control (OFAC) cleared the runway for non-U.S. operators of civil aircraft to send flights into Iran. New  “General License J” authorizes many Boeing, Airbus, and other civil aircraft containing U.S.-origin materials to fly to Iran on “temporary sojourn.” The General License provides a great … Continue Reading

Are You Within Reach of Anti-Money Laundering Enforcement? The Tentacles of Money Laundering Schemes Affect Real Estate Investors Worldwide

The U.S. Treasury Department has signaled the latest focus of its enforcement: real estate ventures with ties to money laundering schemes. Individual real estate investors and companies involved in luxury real estate, real estate development or investment, property management, and escrow or mortgage services around the globe should heed Treasury’s warnings.… Continue Reading

New Business Opportunities in Iran! But Who Will Be Your Banker? Non-U.S. Banks Hesitant to Process Lawful Iran Transactions…and for Good Reason

Highlights: Sanctions relief presents new business opportunities with Iran Most U.S. companies are still prohibited from Iran business, but the U.S. government is encouraging lawful business by non-U.S. companies The line between permitted and prohibited financial transactions by non-U.S. banks is not clear Careful advice of counsel is critical… Continue Reading

Keep Your Frenemies Close: Proposed China Sanctions and the Price of Escalation

On August 30, 2015, the Washington Post broke a story that the Obama administration is developing a package of economic sanctions that will target Chinese companies and individuals who have benefitted from cybertheft. The new sanctions would come at a time when commerce between the two countries is thriving, but political relations are strained.… Continue Reading

The Broader Problem: European Bank Creates an Easy Catch for the Long Arm of U.S. Jurisdiction

On March 12, 2015, Commerzbank AG, Germany’s second largest bank and a global financial institution, agreed to pay $1.45 Billion (yes, with a “B”) in forfeitures and fines to the U.S. Government for violating U.S. sanctions against Iran and Sudan. The amount paid by Commerzbank under the settlement will not be shocking to those who … Continue Reading

Paying the Piper: PayPal Inc. Settles Sanctions Violations with OFAC for $7.7 Million

On March 25, 2015, the Department of Treasury’s Office of Foreign Assets Control (OFAC) announced that PayPal Inc. (“PayPal”) agreed to pay $7.7 million to settle 486 violations of U.S. economic sanctions.  According to OFAC, for several years until 2013, PayPal, one of the world’s largest electronic payment companies, did not have adequate compliance processes … Continue Reading

Accounts and Accountability: Arab Bank Found Liable for Transactions Under the Anti-Terrorism Act

On September 22, 2014, a Brooklyn jury found Arab Bank, Jordan’s largest lender, guilty of violating the U.S. Anti-Terrorism Act for providing financial services to individuals and entities linked to Hamas. Hamas is currently designated as a terrorist organization by the U.S. Treasury Department, Office of Foreign Assets Control (OFAC), and is listed on the … Continue Reading

OFAC Gets Hot, Bothered on Iran and Cuba: How Economic Sanctions Work Today

By: Scott Maberry and Mark Jensen People who practice U.S. economic sanctions law like to talk about how sanctions are policy-oriented, or an engine of U.S. foreign policy.  Whereas some laws may be more opaquely political, economic sanctions and embargoes seem to express most bluntly how international leverage works through regulation.  And yet, a few recent regulatory developments show that the direction that sanctions take is not always predictable. … Continue Reading

International Sanctions – Updates to U.S. Sanctions Laws in 2011

By: David Gallacher and Thaddeus McBride In 2011, the world experienced historic events, particularly with regard to the Arab Spring and the violent repression that followed in nations like Libya and Syria.  2011 witnessed the expansion of a number of international sanctions programs, most particularly tied to political developments in countries such as Iran, Syria, Libya, Sudan, Cuba, and North Korea.  Following is a summary of key developments in U.S. sanctions during 2011, as well as a brief look ahead at what may happen in 2012 in countries such as Iran, Yemen, and Myanmar (Burma).  … Continue Reading
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