October 17, 2016, Covington Alert

Effective today, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) has amended the Cuban Assets Control Regulations (“CACR”) and the U.S. Commerce department’s Bureau of Industry and Security (“BIS”) has amended the Export Administration Regulations (“EAR”) to expand permissible dealings involving Cuba, further easing the longstanding U.S. trade embargo and continuing a policy shift that the Obama Administration announced in December 2014.

Simultaneous with last Friday’s announcement of these changes, President Obama issued a Presidential Policy Directive that outlines a policy of “normalization” as to U.S.-Cuba relations. The directive states that the embargo — elements of which remain in place — is “outdated” and renews calls for Congress to lift the remaining restrictions.

June 9, 2016, Covington Alert

The U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) yesterday published new Frequently Asked Questions (“FAQs”) that help clarify the scope of certain measures taken by the United States in January to ease its sanctions against Iran in accordance with the Joint Comprehensive Plan of Action (“JCPOA”), the multilateral agreement signed in mid-July 2015 in which Iran agreed to accept certain limitations on its nuclear program in exchange for sanctions relief. In a prior alert, we described this sanctions relief in detail, as well as concurrent guidance that OFAC issued addressing many of its aspects.

July 15, 2015, Covington Alert