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 improving Cuban relations. But how did our more substantive predictions fare? Okay, it’s a little hard to tell from the President’s actual speech, which was not full of policy detail. Fortunately, there is the Department of Treasury, whose overworked, understaffed Office of Foreign Assets Control provided a helpful FAQ page, and the White House staff, who produced a fact sheet on the new policy. In any event, nothing is final until OFAC issues regulations to implement the new policy.
Continue Reading Our Cuba Sanctions Predictions: How Did We Do?

By: Scott Maberry and Matthew Riemer

As the new year brings in a new term for the Obama Administration, the pace of Iran sanctions shows no sign of slowing.  As we reported in October and November, Washington’s commitment to denying Iran the ability to advance its nuclear weapons program remains steadfast.  We expect the Iran Freedom and Counter-Proliferation Act of 2012 (IFCPA), included in the National Defense Authorization Act for Fiscal Year 2013, to deal another powerful blow to large sectors of the Iranian economy and significantly expand the universe of “persons” to be placed on OFAC’s List of Specially Designated Nationals and Blocked Persons (the SDN List).
Continue Reading New Law Expands Scope of Iran Sanctions In New Ways

By: Scott Maberry

The U.S. Government has taken yet another step to counter the threat of Iran-sponsored terrorism, this time focusing on Iran’s direct activities in the Western Hemisphere. On December 28, 2012, President Barack Obama signed into law the “Countering Iran in the Western Hemisphere Act of 2012,” H.R. 3783 (112th Congress 2012). The Act requires the U.S. Department of State to develop a strategy to address Iran’s “growing hostile presence and activity in the Western Hemisphere.” The Act lists several concerns about Iran’s presence in the Americas and the Caribbean, including economic and diplomatic initiatives, economic activity, and allegations that Iran is supporting Hezbollah activities in the border areas of Brazil, Argentina, and Paraguay.
Continue Reading New Law To Assess Iranian Activities in the Americas

By: Thad McBride and Cheryl Palmeri

The start of the new year is the perfect time to reflect on the international trade enforcement actions of the past year and to predict what they might mean for the year ahead.  This exercise is made exponentially easier by the “Summary of Major U.S. Export Enforcement, Economic Espionage, Trade Secret, and Embargo-Related Criminal Cases” (the “Enforcement Summary”) which recently was updated through December 6, 2012.  The Enforcement Summary suggests a number of important trends in export enforcement and embargo-related cases.

Continue Reading Iran, China, and Prison: A Recap of 2012’s Major Export Enforcement and Embargo-Related Criminal Cases