June 19, 2017, Covington Alert

On Friday, June 16, 2017, President Donald J. Trump announced a tightening of the United States’ long-standing Cuba embargo, rolling back some of the easing implemented during the Obama Administration and described in our prior client alerts. The Trump Administration’s approach is outlined in a National Security Presidential Memorandum, but the full scope of this policy shift will not be known until the Treasury Department’s Office of Foreign Assets Control (“OFAC”) adopts new regulations in the coming months. As OFAC clarified in its Frequently Asked Questions, none of the changes announced by the President last week take effect until the new regulations are issued.

The U.S. Senate has also passed a bill that would codify existing sanctions and impose new sanctions against Russia, and also impose new sanctions against Iran. This bill now goes to the House of Representatives. Additionally, the boycott of Qatar by Saudi Arabia, the United Arab Emirates, and other countries raises issues under the U.S. antiboycott regimes administered by the U.S. Treasury and Commerce Departments. These recent developments potentially present legal risks for companies operating in Russia and the Middle East.

January 13, 2017, Covington Alert

In response to “positive actions” taken by the Government of Sudan over the past six months, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced today an amendment to the Sudanese Sanctions Regulations (“SSR,” 31 C.F.R. Part 538) that effectively suspends virtually all of the U.S. sanctions against Sudan by authorizing through a general license (hereinafter, the “General License”) all transactions otherwise prohibited by the SSR and two related executive orders (13067 and 13412). The General License will take effect when it is published in the Federal Register, which is scheduled to occur on Tuesday, January 17, 2017.

July 15, 2015, Covington Alert