Cari Stinebower

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  The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is known for imposing hefty penalties for violations of US economic sanctions, with individual violations amounting to up to US $295,141 or twice the value of the transaction, whichever is greater, per prohibited transaction, and overall penalties sometimes running into the hundreds of millions, or even billions, of dollars. Despite this, OFAC historically has not provided much guidance for companies on the…
  Over the last week, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has issued two updated advisories, as well as issued a series of new designations of Specially Designated Nationals (SDNs), highlighting the sanctions-related risks for, and the focus on, the shipping community. Taken together, they provide important guidance for members of the shipping industry—including shipping companies, ship owners, insurance companies, and financial institutions with shipping practices, port operators, and…
Crowell & Moring’s Latin America Practice publishes a Regional Recap each month to highlight some of the most relevant news and trends from the region impacting international trade and investment. To learn more about each issue, please click on the hyperlink below. Major trend: Battling Systematic Corruption Venezuela: A Storm of Political Uncertainty Brazil: Changing Old Ways PROSUR: Colombia Paving a New Path Mexico: A “Free Zone” Nicaragua: Dialogue 2.0? Cuba: A Potential Tsunami of
Following Colombia’s official withdrawal from the intergovernmental regional organization UNASUR (Union of South American Nations), Colombian President Iván Duque announced on January 14 the creation of a new union called PROSUR. President Duque explained that PROSUR would function as an organization for regional coordination and cooperation of public policy, defense of democracy, promotion of the separation of powers, and the fostering of market economies among South American countries. On February 19, Chilean President Sebastian Piñera…
On February 19th, Ecuador’s Anti-Corruption Secretary, Iván Granda, and Minister of Foreign Affairs & Human Mobility, José Valencia, hosted the first meeting for the creation of the International Anti-Corruption Commission. Attendees included the diplomatic corps, members of multilateral organizations, and civil society representatives. Granda indicated that the three objectives of the Commission were: Corruption prevention; Investigation of alleged cases of corruption; and Combating and prosecuting acts of corruption – including the repair and recovery of…
Updates about the current situation in Venezuela have been coming in rapidly. Recently, we wrote about OFAC adding PdVSA to the SDN list. In this podcast, Crowell & Moring’s Cari Stinebower, Eduardo Mathison, and Mariana Pendás provide an overview of recent developments in Venezuela and explain what U.S. companies need to know about how these developments could impact trade.Click on an option below to access the podcast: Crowell.com | SoundCloud   Crowell & Moring’s…
On January 28, 2019, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated Petróleos de Venezuela, S.A. (PdVSA) pursuant to Executive Order (E.O.) 13850 – “Blocking Property of Additional Persons Contributing to the Situation in Venezuela”. Further, OFAC amended General License 3, issued eight (8) new General Licenses, and published a new Frequently Asked Question (FAQ) on the new E.O. – “Taking Additional Steps to Address the National Emergency with Respect…
On December 20, 2018, President Trump signed into law the Nicaragua Human Rights and Anticorruption Act of 2018 (NICA Act). The sanctions listed in the NICA Act are additional and would be complementary to the current sanctions that have already been imposed on Nicaragua by the US Office of Foreign Assets Control (OFAC). The NICA Act aims to block any loan that could be issued by international financial institutions that could benefit the…
Following the imposition of new U.S. sanctions on Russia in April 2018, Russian lawmakers have introduced two draft bills proposing Russian countersanctions against ‘unfriendly’ states, as well as criminalizing compliance with foreign sanctions in Russia. The Countermeasures Bill The first measure, the Draft Bill No. 441399-7 On Measures (Countermeasures) in Response to Unfriendly Actions of the USA and (or) other Foreign States (the Countermeasures Bill) passed both chambers of the Federal Assembly, and was signed…
On May 8, 2018, President Trump announced the United States’ withdrawal from the Joint Comprehensive Plan of Action (JCPOA) pursuant to which the United States had provided relief from certain direct sanctions and even more secondary sanctions. Following his remarks, the president signed a National Security Presidential Memorandum directing the Departments of State and the Treasury to “begin reinstating” U.S. nuclear sanctions that had been lifted in connection with JCPOA implementation. Immediately following the…