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,…
On September 1, 2020, the US Department of State’s Bureau of International Security and Nonproliferation, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), and the US Department of Commerce’s Bureau of Industry and Security issued a joint advisory on North Korea’s ballistic missile procurement activities (“Advisory”). The Advisory, among other things, identifies key participants of North Korea’s ballistic missile procurement and their deceptive tactics and key items, including materials and equipment,…
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 30, 2020, the US Department of State (“State Department”) expanded secondary sanctions targeting Iran’s nuclear, military, and ballistic missile programs under the Section 1245 of the Iranian Freedom and Counter-Proliferation Act of 2012 (“IFCA”) by including 22 specific metals used in connections with such programs in Iran. Sanctions may be imposed on persons who knowingly transfer these 22 materials, in addition to the 4 materials already determined by the State Department in October…