What are international sanctions? What are primary and secondary sanctions? What are extraterritorial effects and how will that impact multinational operations? The changing international sanctions regulations produce dizzying regulatory landscape, and complex as well as confusing compliance environment. To help lift the curtain a bit on this topic, Trade Practitioner José María Viñals (partner, Madrid/Brussels), also … Continue Reading
The latest edition of our transatlantic export controls and sanctions wrap-up is now available. In this publication, we look at the shifting regulatory framework for international trade compliance on both sides of the Atlantic. In this issue, we cover:… Continue Reading
On October 18, 2019, the Bureau of Industry and Security (BIS) of the US Department of Commerce announced that it will further restrict the Cuban regime’s access to goods, including commercial aircraft. This action is in response to Cuba’s domestic situation, as well as its support of the Maduro regime in Venezuela. … Continue Reading
On October 5, 2018, the US Department of the Treasury, Office of Foreign Assets Control (OFAC) announced an agreement with JPMorgan Chase Bank, N.A. (JPMC) to settle potential civil liability arising from 87 apparent violations of the Cuban Assets Control Regulations, the Iranian Transactions and Sanctions Regulations, and the Weapons of Mass Destruction Proliferators Sanctions Regulations. According to OFAC, “the transactions … Continue Reading
On 17 November, OFAC announced a settlement agreement with BCC Corporate SA (BCCC), a Belgium-based credit card issuer and corporate service company, in connection with 1,818 violations of the Cuban Assets Control Regulations occurring between April 2009 and February 2014. During this time, BCCC was a wholly owned subsidiary of Alpha Card Group, which in … Continue Reading
OFAC and US Department of Commerce’s Bureau of Industry and Security (BIS) have each issued new regulations implementing President Trump’s June 2017 National Security Presidential Memorandum on Cuba (the “Cuba NSPM”). On 9 November, OFAC published amendments to the Cuban Assets Control Regulations (31 C.F.R. Part 515) in the Federal Register. The amendments implement the … Continue Reading
Welcome to 2017. The 115th Congress convened on Tuesday, 3 January. U.S. businessman Donald Trump will be sworn in as the 45th President of the United States on Friday, January 20. Trump Transition News. President-Elect Trump continues to announce senior officials who will serve as part of his Administration. The Trump Transition Team noted at … Continue Reading
Cuba – Fidel Castro Passes Away. In the statement released on 26 November, President Barack Obama said of the former Cuban leader: [W]e extend a hand of friendship to the Cuban people. We know that this moment fills Cubans – in Cuba and in the United States – with powerful emotions, recalling the countless ways … Continue Reading
Likely Major Policy Developments President-Elect Trump will enter the White House facing a dramatic decline in global trade growth. A recent World Trade Organization (WTO) report notes that 2016 marks the slowest pace of trade and output growth since the 2008 financial crisis. WTO Director-General Roberto Azevêdo called slowing trade growth “a wake-up call,” … Continue Reading
The U.S. Congress is in recess until after the 8 November elections. The House of Representatives will reconvene on Monday, 14 November, and the Senate the following day. The U.S. International Trade Commission (USITC) published its long awaited Federal Register notice on 14 October regarding the Miscellaneous Tariff Bill (MTB) petition process. Petitions for duty … Continue Reading
In the weeks preceding the 18 February 2016 agreement between the US and Cuba authorising daily US commercial flights between the two countries, regulators at the BIS and The US Treasury Department’s Office of Foreign Assets Control (OFAC) adopted companion rules easing restrictions on trade with Cuba. The BIS Rule, among other things, amends the … Continue Reading
President Barack Obama addressed a joint session of Congress on Tuesday, delivering his final State of the Union (SOTU) address. Although trade is generally not a central theme during a congressional and presidential election year, the President did mention the Trans-Pacific Partnership (TPP) deal near the end of the speech as one example of American … Continue Reading
