Tuesday, the Chairman of the House Appropriations Subcommittee on Transportation released the FY 2016 Department of Transportation, Housing and Urban Development appropriations bill which will be considered by the subcommittee tomorrow. The legislation includes provisions which would, in essence, bar the U.S. government from recertifying any airline or cruise line…
On April 2, 2015 representatives of the United States, Britain, France, Germany, China and Russia (collectively, the “P5+1” countries) announced that they had agreed with the Islamic Republic of Iran on the Parameters for a Joint Comprehensive Plan of Action Regarding the Islamic Republic of Iran’s Nuclear Program (the “Parameters”…
Japanese companies may face major questions about Iran after June 2015. At that time, significant new opportunities could open in one of the world’s largest undeveloped economies and energy reserves, or the door could remain shut and more severe sanctions policies could impact existing business. It is important to plan…
OFAC removal of 45 parties from the list of Specially Designated Nationals deserves attention. On March 24, 2015, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced the removal of 45 parties from the list of Specially Designated Nationals (SDN List). All had previously been designated in relation…
On March 6, 2015, Switzerland extended its measures to prevent the circumvention of sanctions issued by the EU. These correspond to the measures introduced by the EU in December 2014. Switzerland has prohibited all foreign investment in Crimea and Sevastopol. There is a ban on services in several economic sectors,…
On February 12, Sen. Amy Klobuchar (D-MN) introduced Senate Bill 491, the Freedom to Export to Cuba Act. This bipartisan bill is intended to lift the broad embargo on U.S. trade and investment in Cuba, but leaves in place many of the restrictions related to human rights and property claims,…
In December 2014, President Obama made an unexpected announcement signaling a “new course” for Cuba after more than fifty years of comprehensive U.S. sanctions. The changes to U.S. sanctions and export policy under the Cuban Assets Control Regulations and Export Administration Regulations (EAR) implemented in January 2015, although limited, opened…
Among the amendments to the Cuban Assets Control Regulations published by OFAC on January 16 is a provision (section 515.582) that provides that “[p]ersons subject to U.S. jurisdiction are authorized to engage in all transactions, including payments, necessary to import certain goods and services produced by independent Cuban entrepreneurs as…
On January 29, 2015, the Bureau of Industry and Security (BIS) issued a rule amending the Export Administration Regulations (EAR), consistent with the prohibitions contained in Executive Order 13685 that broadly prohibited new investments in, imports from and exports to the Crimea region. Specifically, the Executive Order prohibited “the exportation,…
By Christopher R. Wall, Stephan E. Becker, Nancy Fischer, Aaron R. Hutman and Stephanie J. Rohrer The Office of Foreign Assets Control issued three general licenses today authorizing certain activities that would otherwise be prohibited by Executive Order 13685. This Executive Order became effective on December 19, 2014, and broadly…