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Buh-bye! OFAC calls it quits with Cuba, Narcotics, Iran listings
Earlier today, OFAC removed the following sanctions listings from its SDN List: URREGO ESCUDERO, Carlos Agustin (a.k.a. BENALCAZAR FURMAN, Moshe), Colombia; DOB 19 Feb 1976; citizen Colombia; Cedula...
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November 25, 2015: New Cuba Travel-Related FAQ question 52
On Wednesday, OFAC published an updated version of its Cuban sanctions Frequently Asked Question (FAQ) document. The new question (#52) is about banks' processing of authorized travel transactions vis...
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December 21, 2015: OFAC Updates Cuba Program FAQ
In particular, questions 57-61 regarding insurance were updated: 57. Are insurers that are persons subject to U.S. jurisdiction allowed to provide travel insurance to persons subject to U.S....
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January 26, 2016: Amendments to Cuban regulations being published today
Today (Wednesday, January 27th), OFAC is issuing amendments to the Cuban Assets Control Regulation (CACR) in line with the December 2014 policy changes announced by President Obama “intended to further...
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Amendments to Cuban Asset Control Regulations: The Layman Section
Breaking this up because it's an 18 page PDF. This will make it easier to digest…. And I'm going to skip the sections that non-lawyers will not understand with the current CACR in front of them....
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OFAC Enforcement Action: WATG Holdings & subsidiary run afoul of Cuban sanctions
The firm provided architectural design services for a Cuban hotel between 2009 and 2010, for which it was paid $284,515. The settlement? Roughly half – $140,000, for a non self-disclosed, non-egregious...
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Cuban Asset Control Regulation Amendments, Part 2
Some flavor from the amendments document, in relatively clear English: (d) General license for travel-related transactions incident to exportation or reexportation of certain items. (1) The...
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Cuban Asset Control Regulations, Part 3
§ 515.567 Public performances, clinics, workshops, athletic and other competitions, and exhibitions. (a) General license for amateur and semi-professional international sports federation competitions....
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Cuba Travel Guidance
It's a short one – only 3 questions. Question 1: Which individuals may be transported between the United States and Cuba by a person that qualifies for the general license to provide carrier services?...
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Location, Location, Location: CGG Services Settles with OFAC
CGG Services SA agreed to a settlement of $614,250 for violating the Cuban Asset Control Regulations in new and exciting ways. First, one of the company’s US affiliates supplied goods to a number of...
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Halliburton Settles OFAC Enforcement Action for $304,706
Halliburton Atlantic Limited (HAL) and Halliburton Overseas Limited (HOL) exported goods and services to an oil and gas production consortium which had 5% ownership by Cuba Petroleo (aka Cupet), a...
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March 15, 2016: Cuban Asset Control Regulations Changed
You know, this will take a while to digest – which I will do in subsequent posts. But, long story short, OFAC is amending the Cuban Asset Control Regulations (CACR) to make various things easier to do...
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What’s in the CACR Amendments?
So, here’s what changed last week to the Cuban Asset Control Regulations (CACR): “People to people educational travel” now doesn’t have to be through a sponsoring organization. However, you have to...
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April 21, 2016: OFAC Updates Cuba Sanctions FAQ
On April 21st, OFAC added 8 new questions to the Cuba Sanctions FAQ: 62, 63, 67, 68, 80, 81, 93 and 97: 62. Does § 515.584(d) of the CACR permit authorized U-turn transactions to originate or...
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Today’s lucky OFAC numbers: 43, 50
On Friday, OFAC added 2 new items to its Frequently Asked Questions (FAQ) document for the Cuban sanctions program: 43. May the U.S. dollar be used to conduct transactions in Cuba or with Cuban...
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July 18, 2016: OFAC adds #38, updates #39 in Cuba Sanctions FAQ
On July 18th, OFAC updated question #39, and added a new question 38 in Section III (Travel and Carrier Services) of its Cuba Sanctions FAQ (Frequently Asked Questions): 38. In the case of a customer...
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October 14, 2016: Time to revise the Cuban sanctions again…
On Friday, OFAC issued amendments to the Cuban Asset Control Regulations (CACR), updated its Cuban sanctions FAQ document, issued a Fact Sheet and an updated guidance document about travel to Cuba....
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October 28, 2016: OFAC clarifies, again
Friday, OFAC published guidance for the Sudan, Syria, Iran and Cuba programs regarding the publishing activities general licenses and certain exemptions. Here are the meaty parts: OFAC offers the...
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National Oilwell Varro Draws a Penalty Flag from OFAC
Normally, OFAC just says they have released enforcement information. Not this time – the email I received: Release of OFAC Civil Penalties Information National Oilwell Varco, Inc., a Delaware...
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January 6, 2016: Adios, SDNs!
OFAC removed the following listings associated with the Cuba sanctions program on Friday: ANGELINI, Alejandro Abood, Panama (individual) [CUBA]. BELMEX IMPORT EXPORT CO., LTD., 24 Corner Regent and...
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