US

DOJ ENHANCES AND MAKES PERMANENT FCPA SELF-DISCLOSURE PILOT PROGRAM

On November 29, 2017, the US Department of Justice (DOJ) announced that the Pilot Program it launched in 2016 to encourage companies to self-report potential violations of the federal anti-bribery Foreign Corrupt Practices Act (FCPA) would be made permanent, subject … Continue reading

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Filed under Announcements, Bribery and Corruption, US

OFAC, BIS AND STATE DEPARTMENT PUBLISH NEW REGULATIONS TIGHTENING US SANCTIONS CONCERNING CUBA

On 8 November 2017, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published significant amendments to the Cuban Assets Control Regulations (CACR) and Export … Continue reading

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US AUTHORITIES ISSUE COMPREHENSIVE IMPLEMENTATION GUIDANCE ON NEW US SANCTIONS LEGISLATION

Following our earlier bulletin, on October 31, 2017, the US Department of State and Department of Treasury’s Office of Foreign Assets Control (“OFAC”) posted comprehensive guidance related to the Countering America’s Adversaries Through Sanctions Act of 2017 (“CAATSA”). The new … Continue reading

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Filed under Announcements, Sanctions and Money Laundering, Sector Updates by Herbert Smith Freehills, US

POTENTIAL SANCTIONS IMPOSITION PURSUANT TO US ADMINISTRATION’S ANNOUNCED NEW STRATEGY ON IRAN

President Trump has repeatedly criticised the ‘Iran deal’, referring to it as an ‘embarrassment’ for the United States. On 13 October 2017, he laid out new strategies his administration is taking concerning Iran. In a speech delivered at the White … Continue reading

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TRUMP ADMINISTRATION IMPLEMENTS SECTORAL SANCTIONS TARGETING VENEZUELA

On August 24, 2017, President Trump issued a new Executive Order targeting the current Venezuela regime.  The next day, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced the implementation of broad new “sectoral” sanctions applicable … Continue reading

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Filed under Announcements, Sanctions and Money Laundering, US

US PRESIDENT SIGNS IRAN, NORTH KOREA AND RUSSIA SANCTIONS BILL – WITH TWO SIGNING STATEMENTS

H.R. 3364 (the “Countering America’s Adversaries Through Sanctions Act”) overwhelmingly passed the House and Senate and has now been signed into law by the US President, albeit with two partly critical signing statements (here and here). The law represents significant … Continue reading

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Filed under Sanctions and Money Laundering, US

US PRESIDENT RECERTIFIES IRAN NUCLEAR DEAL AND EXTENDS REVIEW OF SUDAN SANCTIONS

Iran Nuclear Deal Recertified with New Sanctions Imposed On July 17, the US President certified Iranian compliance with the Iran nuclear deal, the Joint Comprehensive Plan of Action (JCPOA). Under the JCPOA, Iran is reducing its nuclear capacity in exchange … Continue reading

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Filed under Sanctions and Money Laundering, US

US to reinstate certain actions against Cuba

On June 16, 2017, President Trump announced a policy framework for the re-imposition of certain US sanctions with respect to Cuba. In particular, the United States' new policy will restore certain restrictions with respect to American investments in the Cuban … Continue reading

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Filed under Sanctions and Money Laundering, US

US Senate votes to impose new sanctions on Iran

The US Senate has voted to impose an array of new sanctions with respect to Iran, related to Iran's alleged activity concerning its ballistic missile program, international terrorism, and arms supply and training. The bill serves as a reminder that, … Continue reading

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Filed under Sanctions and Money Laundering, US

US Senate approves Russia sanctions amendment

A bipartisan US Senate coalition has approved a wide-ranging package of new Russia-related sanctions as an amendment to the Countering Iran's Destabilizing Activities Act of 2017 ("S.722" or "Iran Sanctions Bill") currently pending before Congress. The changes contemplated by these provisions-dubbed-Countering … Continue reading

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Filed under Sanctions and Money Laundering, US