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.