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Inessa Owens

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On October 27, 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) published a final rule amending the Cuban Assets Control Regulations (“CACR”) restricting certain remittance-related transactions to and from Cuba (the “Final Rule”). OFAC also published updated and new Frequently Asked Questions (“FAQs”) related to transactions with Cuba. Significantly, the recent amendments will have the practical effect of making remittances to Cuba more difficult. The Final Rule becomes effective on November 26,…

The US Treasury Department and the US State Department have announced two new rounds of sanctions against Syria, including the first designations under the recently-enacted Caesar Syria Civilian Protection Act (“Caesar Act”).  The first round, announced on June 17, 2020, resulted in the addition of 39 individuals and entities to the List of Specially Designated Nationals and Blocked Persons (“SDN List”) maintained by the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) pursuant Caesar…

On July 14, 2020, President Trump signed into law the Hong Kong Autonomy Act  (“HKAA”) providing for the imposition of sanctions on foreign persons who materially contribute to the undermining of Hong Kong’s autonomy by the Government of the People’s Republic of China (“PRC”) and foreign financial institutions who engage in significant transactions with such foreign persons.  During a press conference announcing the signing of the HKAA, President Trump also indicated that he had signed…

On June 5, 2020, the US Commerce Department’s Bureau of Industry and Security (“BIS”) published: (1) a final rule adding nine Chinese entities to the Entity List (the “XUAR Designees”), and (2) a final rule adding twenty four entities located in China, Hong Kong, and the Cayman Islands to the Entity List (the “Military Designees”). Both sets of designations were announced by the Commerce Department on May 22, 2020 (see announcements here and here), but…