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U.S. Treasury implements Final FIRRMA Regulations

INTRODUCTION - This week, new regulations promulgated by the U.S. Department of the Treasury (the Treasury) went into effect to finalize and comprehensively implement the Foreign Investment Risk Review Modernization Act of...more

CFIUS Creates New Pilot Program for Mandatory Declarations

On Aug. 13, 2018, Congress expanded the authority of the U.S. Treasury Department’s Committee on Foreign Investment in the United States (CFIUS) to review certain transactions resulting in non-US control of US assets,...more

Dealmakers Beware: Trump Expands CFIUS’ Reach

On August 13, 2018, President Donald Trump expanded the powers of the Committee on Foreign Investment in the United States (CFIUS) to review foreign investments in the United States by signing into law the Foreign Investment...more

Buyer Beware: CFIUS's Expanding Reach

Introduction - Although the Committee on Foreign Investment in the United States (CFIUS) has been evaluating foreign investment for implications to U.S. national security interests since 1975, its authority has expanded...more

Trump Administration Re-Certifies Iranian Compliance with the Joint Comprehensive Plan of Action but Applies New Sanctions to...

The Trump administration recently re-certified that Iran is in compliance with the Joint Comprehensive Plan of Action (JCPOA, otherwise known as the “Iran Deal”), thereby extending the sanctions relief afforded to Iran...more

New Iran Designations: OFAC Adds 25 Persons to the SDN List in Response to Iran’s Ballistic Missile Test

On February 3, 2017, the U.S. Office of Foreign Assets Control (OFAC) added 25 persons to its List of Specially Designated Nationals and Blocked Persons (the SDN List, and every person thereon, an SDN) as a result of their...more

OFAC Authorizes Certain Dealings with Russian Security Agency

In its first public statement since the inauguration, the US Department of Treasury’s Office of Foreign Assets Control (OFAC) announced on February 2, 2017, that it had authorized limited dealings with the Federal Security...more

Leaving on a Reconciliatory Note: President Obama Ends His Term with a Substantial Easing of the Sudanese Sanctions Regime

The U.S. Department of the Treasury (Treasury) recently announced a significant relaxation of the U.S. sanctions with respect to Sudan that are currently administered by the Office of Foreign Assets Control (OFAC). The...more

New U.S. Sanctions Concerning Russia: President Obama Logs Out of 2016 with an Amendment to the U.S. Cyber-related Sanctions...

On December 29, 2016, OFAC (the U.S. Department of the Treasury, Office of Foreign Assets Control) imposed sanctions on five Russian entities and four Russian individuals in connection with their alleged efforts to interfere...more

OFAC Expands List of Persons Subject to Sanctions Under Ukraine-/Russia-Related Sanctions Authorities

On September 1, 2016, the Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury (Treasury) designated 37 new individuals and entities as Specially Designated Nationals and Blocked Persons (SDNs)...more

Vienna Deal Brings Iran In From The Cold

After months of wrangling, a deal has finally been reached allowing Iran to develop a peaceful domestic nuclear programme with the lifting of economic and financial sanctions.This is on the strict proviso that Iran does not...more

OFAC Revises the “50% Rule” with Regards to Aggregate Ownership

On August 13, 2014, the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued revised guidance relating to the status of entities owned by individuals or entities whose property and...more

Extension Of The Sanctions Relief Provided For In The Joint Plan Of Action Between The P5+1 And The Islamic Republic Of Iran

On July 18, 2014, the P5+1 (the United States, the United Kingdom, Germany, France, Russia, and China) agreed with Iran to extend their commitments under the Joint Plan of Action (JPOA). The JPOA, originally agreed upon in...more

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