Last week, the Office of Foreign Assets Control (OFAC) issued updates to the Cuban Assets Control Regulations (CACR). The updates are intended to continue the Biden administration’s policy of providing the Cuban people with...more
On 24 September 2020, the U.S. Department of Treasury's Office of Foreign Asset Control (OFAC) announced a settlement with Keysight Technologies, Inc. (Keysight) for sanctions violations committed by its former subsidiary,...more
On 27 February 2020, the Office of Foreign Assets Controls (OFAC) issued General License (GL) 8 authorizing certain humanitarian trade transactions involving the Central Bank of Iran (CBI) that are otherwise prohibited under...more
On September 20, 2019, the world changed for many exporters of agricultural commodities, medicines and medical devices. Previously, those items had been authorized for export to Iran pursuant to a humanitarian general license...more
ANTICORRUPTION DEVELOPMENTS - Telecommunications Company Fined $12 Million for FCPA Violations - On August 29, 2019, The Securities and Exchange Commission (SEC) instituted ceaseand-desist proceedings against...more
ANTICORRUPTION DEVELOPMENTS - Petrobras Settles with U.S. Authorities Over Alleged FCPA Violations - On September 27, 2018, the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC)...more
ANTICORRUPTION DEVELOPMENTS - SEC Proposes Amendments to Whistleblower Award Program - On June 28, 2018, the Securities and Exchange Commission (SEC) proposed amendments to its whistleblower award process for the first...more
In furtherance of President Trump’s 8 May 2018 announcement that the United States would withdraw from the Iran nuclear deal—the Joint Comprehensive Plan of Action (JCPOA)—on 27 June 2018, the U.S. Department of Treasury’s...more
On May 8, 2018, President Trump announced that the United States is pulling out of the Joint Comprehensive Plan of Action (“JCPOA”). The announcement will result in the reimposition of the sanctions that were lifted or waived...more
• This enforcement action highlights the heightened sanctions compliance and enforcement risk that companies face when engaging third-party consultants to perform due diligence on counterparties. U.S. persons must make clear...more
On December 23, 2016, the Treasury Department’s Office of Foreign Assets Control (OFAC) issued a final rule amending the Iranian Transactions and Sanctions Regulations (ITSR) to expand the scope of permissible exports and...more
Effective December 23, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) amended the Iranian Transactions and Sanctions Regulations (ITSR) to expand the scope of medical devices that can be exported to...more
U.S. District Court Judge Richard M. Berman denied a motion to dismiss the indictment in the closely followed criminal prosecution of Reza Zarrab, a Turkish/Iranian businessman charged with conspiring to evade U.S. economic...more
On Friday, July 29, the US Office of Foreign Assets Control (OFAC) issued General License J under the Iranian Transactions and Sanctions Regulations (ITSR). This general license authorizes non-US airlines to fly US origin...more
With the rise of OFAC Sanctions enforcement and compliance issues, companies have to devote significant resources to following changes in OFAC Sanctions. Over the last few years, the US government has significantly altered...more
Since we last spoke of "Implementation Day" established on January 16 under the Joint Comprehensive Plan of Action (see "Implementation Day" Brings Openings for Commercial Aircraft Sales With Iran advisory from January 22),...more