OFAC

On December 20, 2016, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued its latest round of Russian sanctions as part of the ongoing U.S. response to Russia’s 2014 annexation of Ukraine’s Crimean peninsula and its subsequent escalation of conflict in the region. The new sanctions target seven individuals, eight entities, and two vessels. OFAC also added an additional 26 subsidiaries of Russian banks already subject to sanctions to the U.S. Sectoral Sanctions List. The new sanctions come one day after the European Union extended its sanctions against Russia for an additional six months.

On December 15, 2016, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) revised their Frequently Asked Questions Relating to the Lifting of Certain U.S. Sanctions Under the Joint Comprehensive Plan of Action (JCPOA), clarifying procedures related to the potential “snapback” of the JCPOA and the subsequent re-imposition of sanctions.

The U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) and the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) recently announced additional rule amendments intended to continue improving relations between the United States and Cuba by allowing even greater commerce and humanitarian efforts between the two countries. These new OFAC  and BIS  rules take effect today.  The new amendments build on previous amendments which Husch Blackwell LLP’s Technology Manufacturing & Transportation Industry Insider blog summarized here, here, and here.

On October 7, 2016, President Obama signed Executive Order 13742, terminating sanctions on more than 200 Burmese businesses and individuals. The Order eliminates prior restrictions on business with Burmese banks, permits the import of Burmese jadeite and rubies, and allows investment reporting through the State Department’s Responsible Investment Reporting Requirements to be made on a voluntary basis. Burma will now receive duty-free treatment on more than 5,000 products exported to the United States.

On September 1, 2016, the Office of Foreign Assets Control (OFAC) placed sanctions on 37 new individuals and entities to prevent attempts to circumvent U.S. sanctions against Russia, help the private sector with compliance and to foster a diplomatic resolution to the conflict in Ukraine. The new list (found here) includes 17 separatists in eastern Ukraine or Russian-occupied Crimea, including 11 officials operating in Crimea.  18 companies operating in Crimea, including a number of construction, defense and maritime firms, and a Ukrainian charity were added to the Specially Designated Nationals (SDN) list.  The list includes construction companies, PJSC Mostotrest and SGM –Most OOO, which were awarded contracts to complete the Kerch Strait Bridge to connect Russia to Crimea.

Cuba’s Minister of Agriculture, Gustavo Rodriguez Rollero, made an official visit to the U.S. last week together with a delegation of officials from other Cuban ministries.  Minister Rollero’s visit was preceded by a February 2016 visit from Rodrigo Malmierca, Cuba’s Foreign Trade Minister.  These visits marked the first U.S. visits from senior Cuban government officials in over 50 years.  President Obama, U.S. Agriculture Secretary Tom Vilsack and Missouri Governor Jay Nixon have also made their own historic visits to Cuba within recent months.  Secretary Vilsack’s visit included a meeting in Havana to sign a Memorandum of Understanding  (the “MOU”) between the U.S. Department of Agriculture and the Cuban Ministry of Agriculture enabling the two agencies to cooperate in fields such as phytosanitary standards, plant and animal sanitation, organic production methods, climatology and irrigation through collaborative efforts such as information exchange and scientific research.

Shortly before President Obama’s upcoming visit to Cuba, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) and U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) have released new rule amendments in order to permit increased travel, financial transactions and trade between the two countries.

These amended rules remove the sponsoring organization requirement from OFAC’s general license allowing “people to people” travel to Cuba. As a result, U.S. persons may now to travel to Cuba much more easily on their own accord under the “people to people” program. However, persons doing so must still must maintain a full-time schedule of meaningful interactive activities, keep appropriate documentation and satisfy other requirements. Travel to or within Cuba for tourism purposes remains prohibited.

On June 30, the United States, together with its partners in the P5+1, the EU and Iran, agreed to a seven day extension of the Joint Plan of Action (JPOA), which currently halts progress on Iran’s nuclear program in order to continue negotiations towards establishing a comprehensive and enduring solution.  The initial agreement, reached in November 2013, stipulated that the P5+1 (comprised of the United States, the United Kingdom, France, China, Russia, and Germany) would implement narrow and targeted sanctions relief in return for Iran’s continued commitment to limit its nuclear program.