Corporate > AG Deal Diary
15 Mar '18

Akin Gump has issued an alert highlighting two recent op-ed pieces written by senior policy advisor Anya Landau French on the opportunities that remain for U.S. businesses in Cuba, despite policy changes. Due to domestic, economic and geopolitical factors in the U.S. and abroad, 2018 is shaping up to be a critical year for U.S.-Cuba bilateral relations.

Click here to read the full alert.

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12 Feb '18

Trade and sanctions

U.S. sanctions administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) apply to U.S. persons, including companies incorporated in the U.S. and U.S. citizens and permanent residents, and, in certain circumstances, non-U.S. persons. U.S. sanctions fall into three general categories: list-based sanctions, comprehensive country- or region-based sanctions, and sector-based sanctions. List- based sanctions prohibit U.S. persons from engaging in virtually all direct or indirect transactions or dealings with persons designated on OFAC’s list of Specially Designated Nationals and Blocked Persons (SDN List) (or companies owned 50 percent or more by such blocked persons). Comprehensive sanctions broadly prohibit U.S. persons and, in certain instances, non-U.S. persons, from engaging in business activities with specific countries or regions (e.g., Iran, Syria, Cuba, North Korea and the Crimea region), including importing or exporting, directly or indirectly, goods or services to or from such countries or regions, unless authorized by OFAC. Finally, OFAC administers “sectoral” sanctions that prohibit U.S. persons from engaging in certain specified transactions with certain entities operating in strategic sectors of the Russian economy.

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23 Jun '17

This week we highlight Professor John Coffee Jr.’s article “Hobson’s CHOICE: The Financial CHOICE Act of 2017 and the Future of SEC Administrative Enforcement”, analyzing the Financial CHOICE Act and in particular its impact on SEC enforcement. This post was published in the Columbia law school’s blog on corporations and the capital markets.

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20 Jun '17

On June 16, 2017, the Trump administration issued a national security presidential memorandum entitled “Strengthening the Policy of the United States Towards Cuba” (the “Presidential Memorandum”). Related to this announcement, the White House issued a Cuba Fact Sheet, OFAC issued a new set of Frequently Asked Questions (FAQs) and the Department of Transportation also issued a new set of FAQs relating to the President’s announcement.

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10 Feb '17

On February 3, 2017, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a press release announcing sanctions against 25 individuals and entities that the U.S. government has associated with the supply chains of technology and materials being used by Iran to support its ballistic missile program. OFAC also designated individuals and entities acting on behalf of, or providing support to, Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) and Lebanon’s Hizballah. Notably, the OFAC press release emphasizes that these actions are “fully consistent with the United States’ commitments under the Joint Comprehensive Plan of Action (JCPOA)”—the nuclear deal reached with Iran and implemented last year.

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06 Feb '17

On February 2, 2017, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Cyber-related General License (GL) 1, a general license that authorizes certain transactions with Russia’s Federal Security Service (Federalnaya Sluzhba Bezopasnosti or FSB).  GL 1 authorizes U.S. persons (i.e., individuals and companies) to request, receive, use, pay for or deal in licenses, permits, certifications, or notifications issued or registered by the FSB for information technology (IT) products in Russia, provided that (i) the relevant IT goods or technology are subject to the U.S. Export Administration Regulations (EAR) and are licensed or otherwise authorized by the U.S. Department of Commerce’s Bureau of Industry and Security (BIS); and (ii) payment of fees to the FSB for such licenses and other authorization or notification does not exceed $5,000 in any calendar year. GL 1 also authorizes transactions or activities that are necessary and ordinary incident to complying with law enforcement or administrative actions or investigations involving the FSB or rules and regulations administered by the FSB.

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17 Jan '17


On January 13, 2017, the Obama administration announced that it would lift sanctions imposed on Sudan issued under the Sudanese Sanctions Regulations (SSR), which are administered by the Treasury Department’s Office of Foreign Assets Control (OFAC). The action reverses nearly 20 years of U.S. policy toward Sudan, a country that had been the target of a comprehensive trade embargo due to human rights abuses and support for international terrorism. The United States has stated that its decision comes after months of bilateral engagement with Sudan, which has revealed that country’s support for key U.S. foreign policy goals, such as ceasing hostilities in conflict areas, including Darfur, and enhancing counterterrorism cooperation.

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