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On May 2, 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published A Framework for OFAC Compliance Commitments, which details more than 10 pages of long-standing OFAC practices on corporate economic sanctions compliance programs. With this publication, companies operating internationally are now on notice that compliance program elements that used to be simply “best practices” guidance will now be expected by OFAC. With the recent strengthening of certain sanctions regimes…
On March 19, 2019, a never-before-used Cuban embargo measure went into effect that makes it possible for U.S. claimants to sue the Cuban government in U.S. courts for confiscated Cuban property. The measures could be further expanded on April 17, 2019, to permit lawsuits against non-Cuban entities operating in Cuba. Since its enactment, Title III of the 1996 Cuban Liberty and Democratic Solidarity (LIBERTAD) Act has threatened to be a potent weapon against entities that…
As of Nov. 15, 2018, the State Department is adding 16 hotels owned by the Cuban military to the Cuba Restricted List (CRL). As discussed in the November 2017 GT Alert, U.S. Implements President Trump’s Cuba Policy, the Department of State published the CRL, identifying certain entities and sub-entities that are “under the control of, or acting for or on behalf of, the Cuban military, intelligence, or security services.” Except as otherwise authorized, no U.S.…
As reported in our previous GT Alerts, on May 8, 2018, President Trump announced his decision to withdraw the United States from the Iran Joint Comprehensive Plan of Action (JCPOA), and on June 27, 2018, OFAC issued amended regulations and general licenses implementing the withdrawal. The Office of Foreign Assets Control’s (OFAC) re-imposition of Iran sanctions pursuant to the U.S. withdrawal from the JCPOA was set up in two phases, with the first set…
The U.S. government has announced significant increases to the maximum civil penalties for U.S. export controls and sanctions violations. The increases are required by the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015 (the FCPIA Act). Details of the penalty increases are described below and available in the Federal Register, Vol. 81, No. 109, 110, and 127. Additionally, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) has…
Jan. 16, 2016 marked “Implementation Day” of the Iran Joint Comprehensive Plan of Action (JCPOA), as the U.S. initiated the removal of its nuclear-related sanctions against Iran and the EU removed the majority of its existing Iran-related sanctions. The final precondition to Implementation Day was met when the International Atomic Energy Agency (IAEA) issued a report verifying that Iran has fulfilled its initial commitments under the JCPOA. Importantly, while Implementation Day has brought the lifting…
Jan. 16, 2016 marked “Implementation Day” of the Iran Joint Comprehensive Plan of Action (JCPOA), as the U.S. initiated the removal of its nuclear-related sanctions against Iran and the EU removed the majority of its existing Iran-related sanctions. The final precondition to Implementation Day was met when the International Atomic Energy Agency (IAEA) issued a report verifying that Iran has fulfilled its initial commitments under the JCPOA. Importantly, while Implementation Day has brought the lifting…