Today, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) and the US Commerce Department’s Bureau of Industry and Security (“BIS”) issued final rules amending the Cuban Assets Control Regulations (“CACR”) and the Export Administration Regulations (“EAR”), respectively, to implement key policy changes to the US embargo of Cuba (the “Amendments”). The policy changes were originally announced by President Obama on December 17, 2014 (we reported on the President’s December 17th announcement in a…
Today, President Obama announced that the US Government plans to establish diplomatic relations with Cuba and to relax certain aspects of the US embargo of Cuba. More detailed information was made available through the issuance of a White House fact sheet, the “White House FACT SHEET: Charting a New Course on Cuba.” Importantly, none of the announced changes to the embargo are self-executing. As the White House fact sheet makes clear, the changes will only…
On October 6, 2014, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued General License No. 3 under Executive Order 13662 of March 20, 2014. General License No. 3 authorizes all transactions with DenizBank S.A., which are otherwise prohibited under Directive 1 of Executive Order 13662. DenizBank is a private Turkish bank that is owned by Sberbank, a Russian bank that was sanctioned under Directive 1 on September 12, 2014. As such, U.S. Persons are…
On Friday, August 1, 2014, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued an advance copy of a final rule amending the Export Administration Regulations (“EAR”) by, among other things, imposing significant new restrictions on exports, reexports, and in-country transfers of certain goods, software, technology, and data for use in Russia’s oil and gas sector related to deepwater, Arctic offshore, and shale exploration and production operations (the “EAR Amendments”). The EAR…