The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) amended the Cuban Assets Control Regulations (CACR), 31 CFR Part 515, to promote internet freedom in Cuba, support independent Cuban private-sector...more
5/30/2024
/ Amended Regulation ,
Bank Accounts ,
Banking Sector ,
Biden Administration ,
Blocked Person ,
Cuba ,
Cuban Assets Control Regulations (CACR) ,
Economic Development ,
Entrepreneurs ,
Financial Services Industry ,
Foreign Nationals ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Private Sector ,
SDN List
The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) issued General License 44A (GL 44A) on April 17, 2024, replacing and superseding General License 44 (GL 44). On Oct. 18, 2023, OFAC suspended...more
The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) on Oct. 12, 2023, designated two tank vessels and their registered owners as Specially Designated Nationals (SDNs) for allegedly transporting...more
The U.S. Department of Justice (DOJ), Department of Commerce's Bureau of Industry and Security (BIS) and Department of the Treasury's Office of Foreign Assets Control (OFAC) on July 26, 2023, issued a Tri-Seal Compliance Note...more
8/2/2023
/ Bureau of Industry and Security (BIS) ,
China ,
Compliance ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Authority ,
Export Controls ,
Exports ,
Iran ,
Joint Policy Statements ,
Joint Statements ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanction Violations ,
Self-Reporting
The U.S. Department of Commerce's Bureau of Industry and Security (BIS) took a number of actions under the Export Administration Regulations (EAR) on May 19, 2023. Here are some of the key U.S. export control actions...more
5/25/2023
/ Belarus ,
Belarus Sanctions ,
Bureau of Industry and Security (BIS) ,
Commerce Control List ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
FinCEN ,
Globally Harmonized System ,
Iran ,
Military End Use ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Tariffs ,
Ukraine
As an update to an earlier Holland & Knight alert on the same topic, the U.S. Department of the Treasury Office of Foreign Asset Control (OFAC) has published another determination pursuant to Executive Order 14071 expanding...more
2/8/2023
/ Australia ,
Biden Administration ,
Crude Oil ,
Economic Sanctions ,
EU ,
Executive Orders ,
Exports ,
G7 ,
Maritime Transport ,
Military Conflict ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Oil Prices ,
Petroleum ,
Russia ,
Tariffs ,
Ukraine
The U.S., European Union (EU), United Kingdom (U.K.) and many other countries have imposed similar but not necessarily identical sanctions on Russia. In corporate jet transactions, the sanctions laws of several jurisdictions...more
5/10/2022
/ Aircraft ,
Beneficial Owner ,
Due Diligence ,
Economic Sanctions ,
EU ,
Export Controls ,
Federal Aviation Administration (FAA) ,
Office of Foreign Assets Control (OFAC) ,
Prohibited Transactions ,
Russia ,
SDN List ,
U.S. Commerce Department ,
UK ,
Ukraine
In the past week, the White House has launched additional salvos of sanctions against the Russian Federation in response to its continued efforts to undermine the sovereignty and territorial integrity of Ukraine. This Holland...more
3/15/2022
/ Biden Administration ,
Economic Sanctions ,
Energy Sector ,
Executive Orders ,
General Licenses ,
Imports ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Shipping ,
Trade Restrictions ,
Ukraine
The U.S. Department of State, U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) and the U.S. Coast Guard (USCG) on May 14, 2020, issued a 35-page Sanctions Advisory that focuses on sanctions compliance...more
The U.S. Office of Foreign Assets Control (OFAC) on Sept. 25, 2019, designated COSCO Shipping Tanker (Dalian) Co. Ltd. (COSCO Dalian), Kunlun Shipping Company Ltd., and certain other entities and individuals as Specially...more
10/8/2019
/ China ,
Controlled Foreign Corporations ,
Economic Sanctions ,
Executive Orders ,
Exports ,
Iran Sanctions ,
Maritime Transport ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Petroleum ,
Risk Mitigation ,
Safe Harbors ,
SDN List ,
Secondary Sanctions ,
Trump Administration ,
Vessels
• President Donald Trump saying at the recent G20 Summit in Japan that American companies could keep selling products to Huawei Technologies Co. Ltd. (Huawei) was another installment in the drama surrounding the Chinese tech...more
7/17/2019
/ Bureau of Industry and Security (BIS) ,
China ,
Entity List ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Exports ,
Foreign Adversaries ,
Foreign Policy ,
General Licenses ,
Huawei ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Prohibited Transactions ,
Sanction Violations ,
Technology Sector ,
Telecommunications ,
Trade Relations ,
Trade Wars ,
Trump Administration ,
U.S. Commerce Department ,
US Trade Policies
• The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) and the U.S. Department of Commerce's Bureau of Industry and Securities (BIS) announced changes to the Cuban Assets Control Regulations (CACR)...more
6/6/2019
/ Aircraft ,
Airline Passengers ,
Bureau of Industry and Security (BIS) ,
Cuba ,
Cuban Assets Control Regulations (CACR) ,
Export Administration Regulations (EAR) ,
Federal Aviation Administration (FAA) ,
Foreign Relations ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
p2p ,
Sanctions ,
Trump Administration ,
Vessels
• Effective May 2, 2019, the Trump Administration will not continue the waiver against lawsuits under Title III of the Cuban Liberty and Democratic Solidarity (LIBERTAD) Act of 1996, also known as the Helms-Burton Act.
•...more
4/26/2019
/ Civil Liability ,
Cuba ,
Extraterritoriality Rules ,
Foreign Nationals ,
International Travel ,
Office of Foreign Assets Control (OFAC) ,
Personal Jurisdiction ,
Trafficking ,
Trump Administration ,
US State Departments ,
WTO
• National Security Advisor Ambassador John Bolton issued a statement threatening sanctions against non-U.S. banks for facilitating illegitimate transactions with certain Venezuelan individuals and entities.
• This...more
3/14/2019
/ Banking Sector ,
Blocked Entities ,
Cross-Border Transactions ,
Economic Sanctions ,
Executive Orders ,
Foreign Financial Institutions (FFI) ,
Foreign Relations ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Secondary Sanctions ,
Venezuela
• The U.S. Department of the Treasury's (Treasury) Office of Foreign Assets Control (OFAC) has designated five officials affiliated with the regime of Nicolas Maduro pursuant to Executive Order 13850 (E.O. 13850), including...more
• Pursuant to Executive Order 13850 (E.O. 13850), the U.S. Department of the Treasury's (Treasury) Office of Foreign Assets Control (OFAC) designated Petroleos de Venezuela, S.A. (PdVSA), effectively blocking PdVSA's property...more
1/31/2019
/ Banking Sector ,
Blocked Person ,
Economic Sanctions ,
Executive Orders ,
Financial Institutions ,
Foreign Policy ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Petroleum ,
SDN List ,
Trump Administration ,
Venezuela
• The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) revoked certain Iran-related "general licenses" that allowed U.S. and U.S.-owned foreign entities to engage in certain transactions and...more
• President Donald Trump has issued a new Executive Order expanding existing sanctions against the government of Venezuela and its instrumentalities, including the state-owned oil company, Petróleos de Venezuela (PdVSA).
...more
On May 8, President Trump announced that the United States is withdrawing from the multilateral nuclear accord with Iran known as the Joint Comprehensive Plan of Action (JCPOA). The U.S. will reimpose sanctions suspended...more
5/11/2018
/ Aircraft Sales ,
Aviation Industry ,
Cross-Border Transactions ,
Economic Sanctions ,
Exports ,
Foreign Banks ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
Foreign Relations ,
Foreign Subsidiaries ,
General Licenses ,
Iran ,
Joint Comprehensive Plan of Action (JCPOA) ,
Lessor ,
Manufacturers ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Trump Administration
• The United States is withdrawing from the multilateral nuclear accord with Iran known as the Joint Comprehensive Plan of Action (JCPOA).
• The U.S. sanctions waived by President Barack Obama under the JCPOA will be...more
• The U.S. Department of State issued public guidance on sanctions with respect to 39 named entities related to Russia's defense and intelligence sectors. This guidance is issued under Section 231 of the Countering America's...more
11/10/2017
/ Arctic Drilling ,
CAATSA ,
Defense Sector ,
Economic Sanctions ,
Energy Sector ,
Executive Orders ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Russia ,
Secretary of State ,
Secretary of the Treasury ,
Shale Gas ,
SSI List ,
Trump Administration ,
US Department of State
On July 20, 2017, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) announced a $2 million civil monetary penalty against Exxon Mobil Corp., including its U.S. subsidiaries ExxonMobil Development...more
8/3/2017
/ Administrative Procedure Act ,
Arbitrary and Capricious ,
Civil Monetary Penalty ,
Due Process ,
Economic Sanctions ,
Exxon Mobil ,
Fifth Amendment ,
Fines ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Reckless Disregard ,
Russia ,
Sanction Violations ,
SDN List ,
Ukraine
The Trump Administration responded on Feb. 3, 2017, to Iran's latest series of ballistic missile tests by sanctioning certain individuals and companies involved in Iran's efforts to procure ballistic missile technology or...more
On July 14, 2015, the United States, France, China, Russia, the United Kingdom, Germany and the European Union (EU) entered into the Joint Comprehensive Plan of Action (JCPOA) with Iran after years of difficult negotiations....more
7/16/2015
/ Banking Sector ,
Banks ,
C-Suite Executives ,
China ,
Compliance ,
Corporate Counsel ,
EU ,
Foreign Corporations ,
France ,
IAEA ,
Imports ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Petrochemicals ,
Russia ,
SDN List ,
UK ,
UN Security Council ,
United Nations
Executive Order Relating to the Crimea Region -
On Dec. 19, 2014, in a step coordinated with similar sanctions imposed by the European Union (EU), President Obama issued a new Executive Order targeting the Crimea...more
12/29/2014
/ Banking Sector ,
Barack Obama ,
Crimea ,
Defense Sector ,
Energy Sector ,
Executive Orders ,
Exports ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
Sanctions ,
SDN List ,
UFSA ,
Ukraine