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  • Cuba Sanctions, Foreign Countermeasures, General, OFAC

OFAC Fines Foreign Company for Following Applicable Foreign Law

The Office of Foreign Assets Control (“OFAC”) recently announced that it has extracted $204,277 from American Express as a result of 1,818 credit card transactions in the amount of $583,649.43 for purchases made in Cuba. At issue were Mastercard and…

  • Clif Burns
  • December 1, 2017
  • 1 Comment
  • OFAC, SDN List, Zimbabwe Sanctions

Mugabe Leaves, Mnangagwa Arrives, Sanctions Remain

ABOVE: Emmerson Mnangagwa Last Tuesday, while you were thinking about the upcoming Thanksgiving holiday, Robert Mugabe, who has been dictator of Zimbabwe for the last 37 years, resigned.  Then while you were storming the doors of a local brick and mortar on Black…

  • Clif Burns
  • November 27, 2017
  • BIS, CFIUS, DDTC

Proposed CFIUS Legislation: Good News for Cattle Prod Makers, Bad News for Cows

On November 8, 2017, the House and Senate introduced the Foreign Investment Risk Review Modernization Act of 2017 (FIRRMA) proposing the first amendments to the CFIUS process since the Foreign Investment and National Security Act was passed in 2007. Although…

  • Clif Burns
  • November 17, 2017
  • Cuba Sanctions, OFAC

When You Might Not Be Libre To Drink a Cuba Libre in Cuba

One of the things that pops out from the State Department’s Naughty List of Cuban businesses is all the beverage companies on it, which seems odd. I mean, honestly, how much can American tourists spend on TropiCola? How much of…

  • Clif Burns
  • November 9, 2017
  • Cuba Sanctions, OFAC

To Have and Have Not People-to-People Trips to Cuba

The Office of Foreign Assets Control (“OFAC”) today announced the long-awaited (or, perhaps more accurately, long-feared) amendments to the Cuban Assets Control Regulations designed to limit travel by U.S. persons to Cuba. (U.S. persons remain free to travel without restriction to the…

  • Clif Burns
  • November 8, 2017
  • 1 Comment
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