In keeping with the continued efforts of the White House to re-establish diplomatic relations with Cuba, the United States recently modified its stance on travel to Cuba and eased certain export restrictions. Reed Smith’s International Trade & National Security team has authored a client alert that summarizes the policy amendments, and explains the implications for … Continue Reading
In keeping with the Obama Administration’s efforts to normalize relations with Cuba, the U.S. government is making further amendments to CACR and EAR. While the overall embargo is still in place, these amendments will lessen the degree of various restrictions. The effects will be seen in areas including travel, telecommunications and internet-based services, commercial and … Continue Reading
On February 27, 2015, the Financial Crimes Enforcement Network (“FinCEN”) announced a $1.5 million civil penalty against the First National Community Bank of Dunmore, Pennsylvania (“FNCB”), arising from FNCB’s admission that it violated the Bank Secrecy Act (“BSA”) by failing to detect and report suspicious financial transactions. The penalty is concurrent with a $500,000 penalty … Continue Reading
On February 18, 2015 the Commerce Department’s Bureau of Industry and Security (“BIS”) and Treasury Department’s Office of Foreign Assets Control (“OFAC”) published changes to the Export Administration Regulation (“EAR”) and the Sudanese Sanctions Regulations (“SSR”) in order to advance the free flow of information and facilitate communications by the Sudanese people. OFAC’s changes are … Continue Reading
This post was also written by Alexandra E. Allan, Laith Najjar, Tom C. Evans On 24 November 2013, an agreement was reached between the E3+3 (also known as the P5+1, and which includes the United States, United Kingdom, Russia, China, France and Germany) and Iran. This agreement, known as the Joint Plan of Action (JPOA), was … Continue Reading
On August 13, 2014, the Office of Foreign Assets Control (“OFAC”) revised its guidance on the status of entities owned by persons designated on the Specially Designated Nationals List (“SDN List”). Under the new guidance, OFAC will consider an entity to be blocked if it is 50 percent or more owned, directly or indirectly, in … Continue Reading
On April 28, the U.S. Department of Commerce announced a new licensing policy restricting exports of “dual use” items that could contribute to Russia’s military capabilities. Effective immediately, the Commerce Department’s Bureau of Industry and Security (“BIS”) will deny new and pending export license applications to Russia or occupied Crimea of high-technology items that could … Continue Reading
On March 19, the Office of Foreign Assets Control (“OFAC”) issued a general license under the Iranian Transactions and Sanctions Regulations that authorizes several specific forms of academic exchanges with Iran. The newly issued general license – General License G (the “License”) – authorizes qualifying U.S. colleges and universities to engage in certain transactions related … Continue Reading
On November 23, 2013, the White House issued a Press Release (“the Announcement”) outlining the first of a two-step negotiation process between Iran and the United States, the United Kingdom, Germany, France, Russia, and China (the “P5+1”). The Announcement calls for the P5+1 countries to provide limited sanctions relief to Iran in exchange for Iran’s … Continue Reading
This post was also written by Gunjan Talati and Joelle E.K. Laszlo. Guilt by association seems to be a growing trend in government contracts. Under this trend, states are starting to use their contracting authority to promote U.S. foreign policy and impose mandatory debarment for policy violators. In the latest example, companies doing business with Michigan … Continue Reading
In August of this year, President Obama signed the Iran Threat Reduction and Syria Human Rights Act of 2012. This law required presidential action to implement certain restrictions, and today, on October 9, 2012, President Obama issued a new Executive Order (EO): “AUTHORIZING THE IMPLEMENTATION OF CERTAIN SANCTIONS SET FORTH IN THE IRAN THREAT REDUCTION … Continue Reading
Late last night the U.S. Senate voted to approve the Iran Threat Reduction and Syria Human Rights Act of 2012, a vote which the House has taken and approved earlier in the day. The Act now awaits the signature of President Obama. As noted in our earlier coverage, this latest round of sanctions further targets … Continue Reading
On July 11, 2012, the Office of Foreign Assets Control (“OFAC”) implemented two general licenses authorizing the exportation of financial services and new investment in Burma (Myanmar). These general licenses follow earlier announcements that the U.S. government would take steps to ease sanctions on Burma, and follows the lead of Canada and the European Union. … Continue Reading
On July 10, 2012, OFAC announced that Great Western Malting Co. (“Great Western”), a U.S. company, agreed to pay $1.35 million to settle apparent violations of the Cuban Assets Control Regulations. Great Western produces malt for the brewing, distilling and food markets. OFAC’s settlement announcement indicates that Great Western’s U.S.-based personnel provided back-office support for a … Continue Reading
The U.S. Office of Foreign Assets Control (“OFAC”) and Bureau of Industry & Security (“BIS”) announced today that it has reached a settlement with ING Bank N.V. (“ING”) relating to potential liability under various U.S. sanctions against Burma (Myanmar), Cuba, Iran, Libya, and Sudan. The apparent violations date back to conduct that begin in 1994 … Continue Reading
This post was also written by Matthew J. Thomas. Just ahead of this week’s meeting in Baghdad between Tehran and other nations concerning Iran’s controversial nuclear program, the U.S. Senate passed an Iran sanctions bill by a unanimous voice vote. This bill is the Senate counterpart to the “Iran Threat Reduction Act of 2011” (H.R. 1905), … Continue Reading
On May 17, U.S. Secretary of State Hillary Clinton announced in remarks with the foreign minister of Burma (Myanmar) that the U.S. government will be taking action to ease sanctions on Burma in the form of a new general license. A general license is similar to an exception to the sanctions and authorizes the performance … Continue Reading
Significant gains in the development of renewal resources occurred in the past 5 years. Here’s a warning not to blow the advances in wind (get it?, of course you do), solar and other alternative energies. A new danger for government contractors operating in war zones: increased suspensions and debarments. So much for non-lawyer owned law … Continue Reading
Winter is wrapping up here in DC so for those of you just emerging from your hibernation, there is a bit of a dust-up about the Affordable Care Act. Are you a government contractor with an alleged conflict of interest? Have these relationships excluded you from bidding on certain government contracts? Well good news (?), … Continue Reading
Home prices are expected to drop in 2012, which is great unless you just bought your first house. The Comprehensive Contingency Contracting Reform Act of 2012 is looking to beef up congressional oversight of federal contracts. Kneel before the power of the purse! The FCPA Professor gives his take on Transparency International – UK’s Deterring … Continue Reading
***Warning*** Falling Puns: Here’s a bright idea. (For those of you who followed the link, I know what you’re thinking: “Come on Mike, you’re better than this.” Turns out I’m not.) While it’s still a little early for Jolly ‘ole St. Nick to be making his list, the SEC is publishing its naughty list, and … Continue Reading
A little clarity on CBP Regulations. For those of you not paying attention, the UK would really like bribery payments to stop. Here is my post, about a post, about a post. Follow the rabbit hole, for a discussion about small businesses being impacted by premium payments to government contractors. What’s going on with satellites? … Continue Reading
The Wolfsberg Group recently published its Anti-Corruption Guidance, which leads me to assume that someone, somewhere, is drafting Corruption Guidance. Perhaps those old cartoons were on to something? More evidence that when it comes to cloud computing, no one knows what to do. People do bad things on the internet? Say it ain’t so. For … Continue Reading
Of Russians and nuclear energy … Line of the Day goes to Sen. Patrick Leahy (D-VT) from this article about the Civilian Extraterritorial Jurisdictions Act: “CEJA will also protect Americans by providing the option of prosecuting them in the United States.” Finally, what we have all been waiting for, multiple international jurisdictions chomping at the … Continue Reading
