The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) added five new Frequently Asked Questions (FAQs) on 6 January 2017. The new FAQs were in reference to a general license that OFAC issued on October of 2016. The license considerably lessened the ‘180-day’ rule – a restriction that makes foreign-flag vessels wait at least … Continue Reading
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
On March 25, 2015, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) and PayPal, Inc. (“PayPal”) agreed to a $7.65 million settlement to settle potential civil liability for 486 apparent violations of various financial sanctions. Between 2009 and 2013, PayPal, a digital payments processor, apparently processed hundreds of transactions in violation … Continue Reading
As the United States and Russia continue to clash over Russia’s actions in the Ukraine, on September 12, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued additional sanctions further restricting designated Russian financial institutions’ access to capital markets, targeting Russian defense entities, and prohibiting exports to Russian entities that have been specifically … 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 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
U.S. persons traveling to Iran for business can now take heart, because they, as well as most laptops and smart phones, may do so without the need for a license. A recent amendment to the wordily-named “General License with Respect to Certain Services, Software, and Hardware Incident to Personal Communications” (formerly “General License D,” now … Continue Reading
When your work involves export controls, it’s good to remember that reform – especially in the form of decontrol – seldom has an immediate impact. It’s been just over a year since the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) lifted its restrictions on the export and re-export of certain medicines and medical … Continue Reading
As members of the United Nations prepared to descend upon Manhattan’s East Side, the U.S. government was moving to seize a building only 13 blocks away. On Monday, September 16, 2013, following a civil complaint originally filed in 2008 by the Manhattan U.S. Attorney’s Office, the U.S. District Court for the Southern District of New … Continue Reading
This post was also written by Matthew J. Thomas and Charles A. Brown. Yesterday, Treasury’s Office of Foreign Assets Control (OFAC) made dozens of significant additions to its list if Iran-linked sanctioned parties, adding new energy, finance and shipping companies, as well as many new individuals and vessels. An update from our shipping, energy and commodities … Continue Reading
This post was also written by Matthew J. Thomas. ING Bank N.V., a Dutch financial institution, has agreed to pay $619 million in a settlement with the Treasury Department’s Office of Foreign Assets Control (OFAC), the Department of Justice (DOJ) and the Manhattan District Attorney. The settlement is the result of OFAC’s investigation into an … 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
This post was written by Michael J. Lowell. On the heels of the largest penalty settlement to date, OFAC has announced yet another settlement with a foreign bank relating to payments processed through U.S. financial institutions. On June 14, 2012, OFAC announced a settlement with the National Bank of Abu Dhabi (“NBAD”) for $855,000 to … Continue Reading
This post was written by Joelle E.K. Laszlo. What if you issued a general license and no one used it? The Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has faced such a conundrum since March 2010, when it published a final rule amending U.S. regulations on Cuba, Iran, and the Sudan to … Continue Reading
With all that had been going on in Libya, the US Government has been working to ensure that regulations are not prohibiting the Administration’s anti-Gaddafi policy. OFAC recently released some guidance that should ease the burden on those US persons seeking to do business with the anti-Gaddafi regime in eastern Libya. For more information seek … Continue Reading
This post was written by Joelle E.K. Laszlo. In response to the increasingly grave political, commercial, and humanitarian turmoil that Libya has endured in the recent weeks, the international community has combined forces in an effort to subdue Muammar Qadhafi’s brutal regime. The United Nations Security Council has called its Member States to enact, among other … Continue Reading
*Attention* government contracts attorneys: If your friends and loved ones stare blankly at you when you explain what it is you do, it turns out they are not the only ones who are confused. Check out this amusing breakdown of confused experts. New Year, new Congress, new rumblings about government fraud . An attorney involved … Continue Reading
On Monday, December 6, in an effort to run some names against the SDN list, I headed over to OFAC’s website. Much to my surprise I discovered that the Treasury Department had unveiled its newly designed website. To make things even more serendipitous, I stumbled across the Treasury blog. The first post is penned by … Continue Reading
