Cuba
Articles
OFAC in 2019: Enforcement Actions Spotlight Cuba, Mergers and Acquisitions
The U.S. Office of Foreign Assets Control had a very busy year. The agency handed out a record $1.28 billion in penalties in 26 settlements. The enforcement actions provide insight into what was top of mind for the agency and offer clues to companies on how to strengthen their compliance programs. (more…)
An Overview of Cuban Sanctions and Key Tips on How to Deal With the Ongoing Changes
The U.S. and Cuba have always seemed to be at odds. Ever since the Cold War era, when the U.S. severed political ties with Cuba, there has been tension between the two governments.
The Good, the Bad, and the Ugly: The Unintended Consequences of Sanctions from a Population Perspective
The U.S. currently maintains economic sanctions against many countries. Frequently criticized and often viewed as a paradox of U.S. foreign policy, economic sanctions are nevertheless quickly becoming the tool of choice for many countries. Sanctions are so popular in fact that many states and municipalities within the U.S. have also begun to implement their own sanctions regimes. In 2000, the U.S. Supreme Court unanimously held in Crosby v. National Foreign Trade Council that a Massachusetts law restricting state transactions with firms doing business in Burma was preempted by federal statute.
A ‘Modest Proposal’ for Cuba: OFAC, BIS and State Department Implement President’s New Cuba Policy
November 24, 2017
By: EdKraul and, Brian Egan, Keith Huffman, Meredith Rathbone, Jack Hayes, Anthony Rapa, and Peter Jeydel*
Effective November 9, 2017, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Department of Commerce’s Bureau of Industry and Security (BIS) amended the Cuban Assets Control Regulations (CACR) and Export Administration Regulations (EAR), respectively, to implement changes to US Cuba sanctions policy articulated by President Trump in a presidential memorandum issued June 16, 2017. Concurrently, as required by the presidential memorandum, the Department of State published a list of 180 entities and sub entities associated with Cuban military, intelligence, and security services (Cuba Restricted List). (more…)
Trump Sanctions Policies Still Undefined, But Could Affect Many Nations and Compliance Officers – Part 3: Steven Bannon’s “America First” Agenda Looms As Big Factor
January 31, 2017
By: Anna Sayre, Legal Content Writer, SanctionsAlert.com
In this series, we present the comments and assertions made by President Donald Trump and his top assistants concerning economic sanctions and export controls so compliance professionals can make informed decisions as to the likely positions of the new U.S.administration in the next four years. (more…)
What to Expect for Economic Sanctions Under President Trump?
January 13, 2017
By Anthony Rapa, Alexis Early and Peter Jeydel*
President-elect Trump has made bold and surprising pronouncements about what he may do after January 20 in the field of international affairs, and these foreign policy choices are likely to have a significant impact on the future course of U.S. economic sanctions programs targeting Iran, Cuba, Russia and other areas. Mr. Trump has said he would terminate the Iran nuclear deal, and with it the sanctions rollback that has taken place over the past year, although actually convincing the rest of the world to re-impose sanctions on Iran would be a monumental feat of diplomacy. On Cuba, Mr. Trump has given reasonably clear signals both that he would support the recent easing of sanctions and that he would reverse it, so the actual policy of the incoming Administration is hardly better than a 50/50 guess at this stage, though with the odds slightly favoring some tightening of sanctions. Russia may be different. That is one area in which Mr. Trump’s statements and actions point to a real possibility of a wholesale change in U.S. policy, although bipartisan congressional concerns with Russia may present a major obstacle to radically changing the current state of affairs, at least without significant concessions by Russia. (more…)
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