President Trump Announces Changes to Cuba Sanctions Program

On June 16, President Trump announced two impending, significant changes to the Cuba sanctions program, which will impact U.S. persons traveling to Cuba. In general, to travel to Cuba a U.S. person must fit within one of 12 categories authorized by OFAC. Individual people-to-people travel, which was under the general category of educational activities and […]

President Obama Sanctions Russian Entities and Individuals for Tampering with Election

On December 29, 2016, President Obama took action to expand the scope of the Department of the Treasury’s Cyber-related Sanctions Program to include, among other things, tampering with election processes.  Specifically, the President issued an Executive Order, Taking Additional Steps to Address the National Emergency with Respect to Significant Malicious Cyber-Enabled Activities. This Executive Order […]

Did Trump Violate the Cuba Sanctions?

Newsweek broke a story that Donald Trump’s company may have violated the Cuban Assets Control Regulations (CACR). Specifically, Newsweek claims that “[d]ocuments show that the Trump company spent a minimum of $68,000 for its 1998 foray into Cuba at a time when the corporate expenditure of even a penny in the Caribbean country was prohibited without U.S. government approval.”

Eliminating Terrorist Financing Without Damaging Legitimate Transactions

Eliminating Terrorist Funding while Enhancing Legitimate Commercial Transactions and Family Remittances There is consensus that financing terrorism, via the international financial system, must be systematically eradicated while maintaining channels for legitimate commercial and family-related financial transactions.  Unfortunately, many international banking conglomerates refuse to do business with certain countries altogether, as their costs of compliance outweigh […]

New OFAC Secondary Sanctions Against Hizballah

OFAC Issues Secondary Sanctions for Foreign Banks Doing Business with Hizballah On April 14, 2016, the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued new secondary sanctions (found in 31 C.F.R. 566 (pdf)) to implement the Hizballah International Financing Prevention Act of 2015. The new secondary sanctions target foreign financial institutions […]

A Closer Look at OFAC’s General License H

Back in July (2015) the permanent members of the UN Security Council (China, France, Russia, the United Kingdom, and the United States), Germany (collectively the P5+1), the European Union, and Iran reached a Joint Comprehensive Plan of Action (JCPOA) to ensure that Iran’s nuclear program would be exclusively peaceful.

OFAC Fines Barclays Bank Over Shadow Blocked Entities

Barclays Bank Pays Millions to Settle Sanctions Violations Involving Shadow Blocked Entities On February 8, 2016, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a settlement between the agency and Barclays Bank Plc regarding apparent violations of the Zimbabwe Sanctions Regulations (ZSR). Specifically, Barclays (including its New York branch), processed […]

Cash Purchases May Complicate Real Estate Buys From Sanctioned Countries

Heightened Scrutiny of Real Estate Cash Purchases May Complicate Future Buys by Those Tied to Sanctioned Countries On January 13, 2016, the Financial Crimes Enforcement Network (FinCEN) issued two new Geographic Targeting Orders (GTOs) that will temporarily require US title insurance companies to identify the natural persons behind companies used to pay “all cash” for high-end residential […]

North Korea’s Global Weapons Proliferation Network Targeted by OFAC Sanctions

On December 8th, 2015, the Treasury Department’s Office of Foreign Assets Control (OFAC) took aim at the North Korean government’s attempts to procure weapons of mass destruction (WMDs) and related materials for production, presumably for the assembly of a strategic rocket force. Six North Korean nationals and three North Korean shipping companies have been added […]