Baker McKenzie

Trump Administration Implements New Restrictions on Travel to Cuba and Limits Types of Aircraft and Vessels Authorized to Travel to Cuba

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On Tuesday June 4, 2019, the Trump Administration announced additional changes to its Cuba policy, further restricting group people-to-people educational travel and limiting the types of aircraft and vessels authorized to travel to Cuba on temporary sojourn. Tuesday’s actions are intended to prevent travel from the United States to Cuba from enriching the Cuban military, intelligence, and security services. These changes, which took effect on June 5, 2019, are a further step toward implementation of the National Security Presidential Memorandum of June 16, 2017 “Strengthening the Policy of the United States Toward Cuba” and the Administration’s intent to restrict non-family travel to Cuba as announced by the President on April 17, 2019. Please see our blog posts covering these prior developments here and here.Read more…

Alison J. Stafford Powell
Ms Stafford Powell advises on all aspects of outbound trade compliance, including compliance planning, risk assessments, licensing, regulatory interpretations, voluntary disclosures, enforcement actions, internal investigations and audits, mergers and acquisitions and other cross-border activities. She develops compliance training, codes of conduct, compliance procedures and policies. She has particular experience in the financial services, technology/IT services, travel/hospitality, telecommunications, and manufacturing sectors.
http://www.bakermckenzie.com/AlisonStaffordPowell
Lise S. Test
Ms. Test advices clients on issues relating to licensing, regulatory interpretations, enforcement actions, internal investigations and compliance audits, as well as the design, implementation and administration of compliance programs. She also advises clients on the extra-territorial application of trade compliance-related regulations in cross-border transactions.
http://www.bakermckenzie.com/LiseTest
Daniel Andreeff
Daniel Andreeff’s practice focuses on US economic and trade sanctions, including those targeting Iran, Russia, Cuba, Syria, and North Korea, export controls, and anti-boycott laws. He represents clients in national security reviews before the Committee on Foreign Investment in the United States (CFIUS), and has experience in federal court litigation and congressional investigations. His pro bono practice includes providing sanctions and export control advice to a global humanitarian NGO.
https://www.bakermckenzie.com/en/people/a/andreeff-daniel

US Government Imposes New Sanctions on Iran-related Trade in Iron and Copper and Additional Sanctions on Trade in Steel and Aluminum

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On May 8, 2019, President Trump issued Executive Order 13871 (the “Iran Metals EO”) imposing sanctions on the iron, steel, aluminum, and cooper sectors of Iran subject to a 90-day wind-down period that will expire on August 6, 2019. Although the sale, supply or transfer to/from Iran of steel and aluminum is already targeted by Section 1245 of the Iran Freedom and Counter-Proliferation Act of 2012, the Iran Metals EO expands upon those sanctions and further targets the Iranian iron and copper sectors.Read more…

Bart M. McMillan
Mr. McMillan's practice involves compliance counseling; compliance programs; licensing; compliance reviews; internal investigations; voluntary disclosures; administrative enforcement actions; criminal investigations; customs inquiries, audits, detentions, and seizures; and trade-compliance due diligence and post-acquisition integration in mergers and acquisitions. His practice includes matters that implicate the US International Traffic in Arms Regulations (ITAR), US Export Administration Regulations (EAR), US National Industrial Security Program (NISP), the US Committee on Foreign Investment in the United States (CFIUS), and equivalent non-US laws. Mr. McMillan regularly advises on and represents clients in matters involving technology, including its control, protection, accidental disclosure, diversion, or unauthorized collection. Mr. McMillan has extensive experience working with companies in the aerospace and defense industry, as well as companies in the Middle East and other parts of Asia.
http://www.bakermckenzie.com/BartMcMillan
Lise S. Test
Ms. Test advices clients on issues relating to licensing, regulatory interpretations, enforcement actions, internal investigations and compliance audits, as well as the design, implementation and administration of compliance programs. She also advises clients on the extra-territorial application of trade compliance-related regulations in cross-border transactions.
http://www.bakermckenzie.com/LiseTest
Daniel Andreeff
Daniel Andreeff’s practice focuses on US economic and trade sanctions, including those targeting Iran, Russia, Cuba, Syria, and North Korea, export controls, and anti-boycott laws. He represents clients in national security reviews before the Committee on Foreign Investment in the United States (CFIUS), and has experience in federal court litigation and congressional investigations. His pro bono practice includes providing sanctions and export control advice to a global humanitarian NGO.
https://www.bakermckenzie.com/en/people/a/andreeff-daniel

Trump Administration To End Suspension of Title III of Helms-Burton and Impose Additional Restrictions on Cuba

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On April 17, 2019, the Trump Administration announced several decisions that mark a significant shift in US policy toward Cuba, most notably by declaring that the United States will no longer suspend Title III of the LIBERTAD Act of 1996, which is also known as the Helms-Burton Act.Read more…

Janet K. Kim
Ms. Kim focuses on outbound trade compliance issues that arise under US economic sanctions, export control laws, investment restrictions, anti-boycott regulations, anti-money laundering laws and the Foreign Corrupt Practices Act. She represents and advises US and non-US companies in criminal and regulatory proceedings, internal investigations, and compliance audits relating to these areas of law. She also advises on the extraterritorial application of these laws in cross-border transactions, including mergers and acquisitions, joint venture arrangements, and other international commercial activities. Her practice includes the development and implementation of workable, risk-based internal compliance programs and procedures for companies in a wide range of industries.
http://www.bakermckenzie.com/JanetKim
Paul D. Burns
Paul Burns has over 30 years of experience advising clients on all aspects of international trade and commodity tax, including significant experience advising on Canadian customs and export control matters. Paul has assisted multinational corporations on a multitude of trade matters, including valuation, tariff classification, rules of origin, marking, standards, remissions and drawbacks; anti-dumping and subsidies; export and import controls; trade sanctions; blocking measures; the Controlled Goods Program; free trade agreements, including the North American Free Trade Agreement (NAFTA); and Goods and Services Tax/Harmonized Sales Tax. He has advised and assisted with audits (both internal and by regulatory authorities), the development of customs strategies and compliance programs, and appealing unfavorable determinations by governmental authorities, including appeals before the Anti-dumping Tribunal, the Canadian International Trade Tribunal and Binational Panels established under the Canada-US Free Trade Agreement, as well as NAFTA.
http://www.bakermckenzie.com/PaulBurns
Sunny Mann
Sunny Mann is a Partner in the Compliance & Investigations Group of Baker & McKenzie’s London office. He has also worked in our Firm’s Washington DC,New York and Sydney offices. He advises clients on compliance with respect to international trade and anti-bribery rules. He has advised numerous FTSE 100 and Fortune 100 clients on general compliance, risk assessments, systems and controls, training, audits, as well as government investigations and disclosures. He also spent 9 months working on secondment with a major UK mobile network operator and a further 3 months on secondment with a major manufacturer of high-tech consumer goods. The Legal 500 described Sunny as “highly rated” and “‘excellent’, with a ‘calm’ and ‘very practical’ approach”. He is a Visiting Professor at the College of Europe (Bruges), the leading institute for post-graduate European studies, where he teaches a Masters course on corporate compliance.
http://www.bakermckenzie.com/SunnyMann
Brian Cacic
Brian Cacic focuses his practice primarily on the area of Canadian customs, trade sanctions, and export controls. He has worked on numerous customs issues, including customs valuation, tariff classification, rules of origin, marking, remissions and drawbacks, anti-dumping and subsidies. He has also advised clients on the application of Canadian export controls to dual-use items, particularly items containing cryptography, as well as nuclear devices and materials, military goods, and missile control and avionics equipment. He has also advised extensively on the application of Canadian trade sanctions to business activities involving Iran, Syria, and Libya. In addition, Brian advises on Canadian commodity tax issues and regulatory compliance issues in the areas of food and drugs, telecommunications and radio communications, and environmental product stewardship.
http://www.bakermckenzie.com/BrianCacic
Lise S. Test
Ms. Test advices clients on issues relating to licensing, regulatory interpretations, enforcement actions, internal investigations and compliance audits, as well as the design, implementation and administration of compliance programs. She also advises clients on the extra-territorial application of trade compliance-related regulations in cross-border transactions.
http://www.bakermckenzie.com/LiseTest
Daniel Andreeff
Daniel Andreeff’s practice focuses on US economic and trade sanctions, including those targeting Iran, Russia, Cuba, Syria, and North Korea, export controls, and anti-boycott laws. He represents clients in national security reviews before the Committee on Foreign Investment in the United States (CFIUS), and has experience in federal court litigation and congressional investigations. His pro bono practice includes providing sanctions and export control advice to a global humanitarian NGO.
https://www.bakermckenzie.com/en/people/a/andreeff-daniel

OFAC Extends Authorization for Transactions w/ PDVH and CITGO and Extends Wind Down of Contracts and Trades Involving Certain Bonds and Securities Until May 2019

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On March 14, 2019, OFAC reissued General License 7 (“GL 7”) as General License 7A (“GL 7A”) to extend the general license’s authorization for certain activities involving PDV Holding, Inc. (“PDVH”) and CITGO Holding, Inc. (“CITGO”). While the original GL 7(a) was set to expire on July 27, 2019, GL 7A(a) automatically renews on the first day of each month, and is valid for a period of 18 months from the last renewal date. GL 7A(a) authorizes certain transactions with PDVH, CITGO, and their subsidiaries that would otherwise be prohibited as a result of the designation of their parent, Petroleos de Venezuela, S.A. (“PdVSA”), on January 28, 2019 under Executive Order 13850. We note that the separate petroleum-related provision that appears in GL 7(b) has not changed, and still expires on April 28, 2019. GL 7A(b) continues to authorize PDVH, CITGO, and their subsidiaries to engage in transactions ordinarily incident and necessary to the purchase and importation of petroleum and petroleum products from PdVSA (and any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest). Our prior blog posts on the scope of GL 7 are here and here.Read more…

Bart M. McMillan
Mr. McMillan's practice involves compliance counseling; compliance programs; licensing; compliance reviews; internal investigations; voluntary disclosures; administrative enforcement actions; criminal investigations; customs inquiries, audits, detentions, and seizures; and trade-compliance due diligence and post-acquisition integration in mergers and acquisitions. His practice includes matters that implicate the US International Traffic in Arms Regulations (ITAR), US Export Administration Regulations (EAR), US National Industrial Security Program (NISP), the US Committee on Foreign Investment in the United States (CFIUS), and equivalent non-US laws. Mr. McMillan regularly advises on and represents clients in matters involving technology, including its control, protection, accidental disclosure, diversion, or unauthorized collection. Mr. McMillan has extensive experience working with companies in the aerospace and defense industry, as well as companies in the Middle East and other parts of Asia.
http://www.bakermckenzie.com/BartMcMillan
Lise S. Test
Ms. Test advices clients on issues relating to licensing, regulatory interpretations, enforcement actions, internal investigations and compliance audits, as well as the design, implementation and administration of compliance programs. She also advises clients on the extra-territorial application of trade compliance-related regulations in cross-border transactions.
http://www.bakermckenzie.com/LiseTest
Daniel Andreeff
Daniel Andreeff’s practice focuses on US economic and trade sanctions, including those targeting Iran, Russia, Cuba, Syria, and North Korea, export controls, and anti-boycott laws. He represents clients in national security reviews before the Committee on Foreign Investment in the United States (CFIUS), and has experience in federal court litigation and congressional investigations. His pro bono practice includes providing sanctions and export control advice to a global humanitarian NGO.
https://www.bakermckenzie.com/en/people/a/andreeff-daniel


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