Picture your company being hauled into U.S. court to defend litigation for your Cuba business that is lawful in your home country. That is the scenario that the Trump administration and Cuba hawks in Congress are aiming to arrange. The Trump administration is preparing to part the practice of past presidents to allow U.S. persons … Continue Reading
The Trump Administration has made good on its promise to cut back on the liberalized Cuban policy implemented by the Obama Administration with a new regime that introduces new travel restrictions as well as broad prohibitions on “direct financial transactions” between persons subject to the jurisdiction of the United States and parties on a new … Continue Reading
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
According to reports published this week, the Trump Administration is preparing to release the results of its policy review on Cuba in the “coming weeks.” We don’t have a crystal ball (or a leaking insider). But we continue to believe that when you eliminate the impossible, what you have left (however improbable) may be the … Continue Reading
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
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
With more flights, relaxing regulations, a historic presidential trip to Cuba, and news of hospitality services expanding into Cuba, the pathway into Cuba for hotels and hospitality companies seems smooth. But businesses should look out for the potential hurdles and compliance risks. Don’t fret – we can help you welcome your guests.… Continue Reading
In a move that may honestly mean more to America than to Cuba, the White House has announced that President Obama will remove Cuba from the U.S. list of “State Sponsors of Terrorism.” As we reported here, the U.S. Department of State has listed Cuba as a state sponsor of terrorism pursuant to the Export … Continue Reading
One aspect of the dramatic shift in U.S. policy toward Cuba that has not been widely reported is a relaxation of the old rule prohibiting imports of most Cuban goods and services. Under the new rules, if your Cuban supplier is one of a small but vibrant class of entrepreneurs on the island, there is … Continue Reading
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
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.
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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).
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