OFAC Fines Navigators Insurance Company without Compliance Program for Apparent Violations of Various Sanctions Programs. Several interesting things stand out regarding OFAC’s enforcement action against Navigators Insurance Company (“Navigators”).  On August 6, 2015, OFAC entered into a settlement agreement with Navigators to settle potential liability for apparent violations of the North Korea, Iran, Sudan, and […]

After more than 53 years of hostility beginning with the outbreak of the Cuban revolution, diplomatic relations between the United States of America and the Cuban government are going to be restored.[1] The normalization of the relationships between the two countries began on December of last year and culminated on April 2015 when, for the […]

The Agreement concluded by the six world powers and the Islamic Republic of Iran in regard to its nuclear program, represents an historic moment in the diplomatic relations between the United States and Iran and, simultaneously, opens to the American business-world the possibility of new and previously unimaginable opportunities. Though the Joint Comprehensive Plan of […]

Impact on European Banks and Companies Click Here For Part 2 As stated in Part 1 of this series, the secondary sanctions system also impacts European companies, and this is through Executive Order 13608 signed by President Obama on May 1, 2012.  This Order gave to the Department of the Treasury the authority to impose […]

Impact on European Banks and Companies Click Here For Part 1 Click Here For Part 3 Executive Order 13622, signed by President Obama, allows the possibility of imposing sanctions against any foreign financial institutions conducting or facilitating any significant financial transaction with the Iranian state oil companies, for the purchase of petroleum or petrochemical products.[1] […]

Impact on European Banks and Companies The American sanctions system against the Islamic Republic of Iran found its origins some years after the outbreak of the Iranian Revolution of 1979, becoming more restrictive in 1995 when President Clinton (see right) prohibited U.S. persons and entities from engaging in most transactions with Iran.[1] These restrictions concerned […]

Legal & Practical Challenges to Representing Alleged Foreign Narcotics Traffickers Foreign nationals face several unique challenges when forced to appear in the United States to face allegations that they are narcotics traffickers.  Many foreign nationals facing extradition to the United States for narcotics trafficking have been indicted by at least one grand jury.  The grand […]

FinCEN: Geographic Targeting Order Issued Against ~700 Miami Businesses; Requires Implementation of Elevated Anti-Money Laundering Controls. On April 15, 2015, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) imposing additional anti-money laundering controls against businesses in Miami that export electronics.  This rarely utilized authority was last […]

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) commonly issues general licenses to sharpen and fine tune its country-based sanctions programs to minimize unintended consequences.  On April 13, 2015, OFAC issued a new general license in the Syrian Sanctions Regulations, promulgated pursuant to Executive Order 13338.  This new general license authorizes […]

On April 1, 2015 the President issued Executive Order 13694: Blocking the Property of Certain Persons Engaging in Significant Malicious Cyber-Enabled Activities.