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  On August 7, 2018, EU’s newly updated Blocking Statute entered into force. The Blocking Statute generally forbids EU citizens and established entities, residents, and persons physically in the EU from complying with a variety of U.S. measures imposing secondary sanctions on Iran, including the Iran Sanctions Act of 1996, the Iran Freedom and Counter-Proliferation Act of 2012, the National Defense Authorization Act for Fiscal Year 2012, and the Iran Threat Reduction and Syria Human…
On Monday, August 6, 2018, President Trump issued a new Executive Order (New Iran EO) that reimposes Iran sanctions previously revoked as part of the Joint Comprehensive Plan of Action (JCPOA), consolidates the relevant authorities into one single document, and broadens the scope of previous sanctions restrictions. This action coincides with the expiration of the 90-day wind down period for a number of transactions previously authorized as part of the Agreement. OFAC also updated and…
On June 27, in accordance with President Trump’s May 8, 2018 decision to withdraw from the Joint Comprehensive Plan of Action (JCPOA), the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) revoked two Iran-related General Licenses and amended the Iranian Transactions and Sanctions Regulations (ITSR), 31 C.F.R. part 560, to reflect the re-imposition of sanctions. OFAC also updated previously issued Frequently Asked Questions on the President’s announcement. These actions represent the first…
On March 26, 2018, the U.S. Court of International Trade (CIT) dismissed U.S. Customs and Border Protection’s (CBP) attempt to collect $4.5 million in penalties against a Canadian textile company, Tricots Liesse 1983, Inc. (Tricots).  U.S. v. Aegis Security Insurance Co. and Tricots Liesse 1983 Inc., Slip. Op. 18-29. Tricots produces quality knit fabrics and sells its fabrics to high-end U.S. swim and active wear producers. Fabric imports made from NAFTA yarn are duty…
Kansas Judge Rules that Class Action over CareCentrix Data Breach may Proceed On December 19, 2016, in Hapka v. Carecentrix, the United States District Court for the District of Kansas denied CareCentrix, Inc.’s (CareCentrix) motion to dismiss a class action suit arising from a data breach affecting CareCentrix’s personal and tax information regarding thousands of employees.  The Court found that plaintiff Sarah Hapka, individually and on behalf of all others similarly situated, met the Article…
The AMA recently adopted a set of principles on mHealth applications (mHealth apps) and other similar digital health tools, to guide coverage and payment policies and the AMA’s advocacy efforts. While many have touted the potential health benefits of mHealth apps and digital devices, the AMA also raises concerns about the potential health and safety risks that these apps can pose to patients along with privacy and security risks. In developing a set of principles…
Illinois State Court Issues First Settlement under Biometric Law On December 1, 2016, the Cook County Circuit Court in Illinois approved what is being reported as the first settlement under the state’s Biometric Information Privacy Act, 740 ILCS 14/1 (BIPA or the Act).  BIPA provides a private right of action against companies that fail to satisfy certain requirements for the collection, retention, and destruction of biometric information, and is an example of the more broad…
On October 25, 2016, the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a new Advisory to Financial Institutions on Cyber-Events and Cyber-Enabled Crime as well as a related list of Frequently Asked Questions (FAQs). The Advisory provides guidance to financial institutions on FinCEN’s expectations with regard to: (1) reporting cyber-enabled crime and cyber-events through Suspicious Activity Reports (SARs); (2) including relevant and available cyber-related information (e.g., Internet Protocol (IP) addresses with timestamps,…
Aug.17.2016 FinCEN has looked under the hood of luxury real estate purchases in Manhattan and Miami, does not like what it sees, and now has expanded its investigation to include six major metropolitan areas. On July 27, the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced new Geographic Targeting Orders (GTOs or Orders) temporarily requiring certain U.S. title insurance companies that receive the Orders to identify and report the natural-person beneficial owners of…