Financial services regulatory reform continues to evolve in 2019. As we observe the changing landscape, here is the Summer Spotlight Edition of our reference tool, which provides context and summarizes current developments across a range of key regulatory areas, agencies and actors. We will continue to track these issues and
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Economic Sanctions
U.S. Government Takes Aim at China With Entity List Additions and New Executive Order
On May 21, 2019, the Department of Commerce published a final rule adding Huawei Technologies Co. Ltd and 68 of its non-U.S. affiliates located in 26 countries (collectively, “Huawei”) to the Bureau of Industry and Security’s (“BIS”) Entity List. Commerce had previously announced its intention…
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U.S. Expands Sanctions Targeting Iran’s Metals Sector
On May 8, 2019, the one-year anniversary of his decision to end the United States’ participation in the Joint Comprehensive Plan of Action (“JCPOA”) with Iran, President Trump issued a new Executive Order “Imposing Sanctions with Respect to the Iron, Steel, Aluminum, and Copper Sectors of Iran” (the…
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OFAC Publishes Guidance on Sanctions Compliance Programs
On May 3, 2019, the Treasury Department’s Office of Foreign Assets Control (“OFAC”) published A Framework for OFAC Compliance Commitments (the “Compliance Framework”), a guidance document that sets forth OFAC’s views of the essential elements of an effective economic sanctions compliance program (“SCP”). OFAC…
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U.S. Department of State to Cancel Iranian Oil Waivers
Posted in Economic Sanctions, OFAC
On April 22, 2019, Secretary of State Mike Pompeo announced that the waivers issued to China, Greece, India, Italy, Japan, South Korea, Taiwan and Turkey, which allow them to continue to import Iranian oil after the United States fully reinstated secondary sanctions against Iran last fall, will expire on May…
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U.S. Government Targets “Three Stooges of Socialism” with New Measures Against Cuba, Venezuela, and Nicaragua
In separate statements on April 17, 2019 coinciding with the anniversary of the Bay of Pigs invasion, U.S. Secretary of State Mike Pompeo and National Security Adviser John Bolton announced several measures intended to increase pressure on Cuba, Venezuela, and Nicaragua, in response to corruption, human rights abuses, and political…
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U.S. Government Adds to Sanctions Against the IRGC with Unprecedented FTO Designation
Posted in Economic Sanctions, OFAC
On April 8, 2019, the U.S. State Department announced its intent to designate Iran’s Islamic Revolutionary Guard Corps (“IRGC”) as a Foreign Terrorist Organization (“FTO”) under section 219 of the Immigration and Nationality Act, 8 U.S.C. § 1189. The designation will take effect upon publication in…
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In Unprecedented but Mostly Symbolic Move, State Department Allows Some Claims under Title III of the Libertad Act
Posted in Economic Sanctions, OFAC
On March 4, 2019, the U.S. State Department announced that, for the first time, it would permit actions under Title III of the Cuban Liberty and Democratic Solidarity (Libertad) Act of 1996, Pub. L. 104-114 (the “Libertad Act”), which authorizes U.S. nationals that own claims to property…
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Davis Polk Financial Services Regulatory Reform Tool—New Congress Edition
Financial services regulatory reform continues to evolve in 2019. As we observe the changing landscape, here is the New Congress Edition of our reference tool, which provides context and summarizes current developments across a range of key regulatory areas, agencies and actors. We will continue to track these issues and…
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OFAC Designates PdVSA
On January 28, 2019, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) sanctioned Petroleos de Venezuela S.A. (“PdVSA”), Venezuela’s state-owned oil company, pursuant to Executive Order (“E.O.”) 13850 for operating in the oil sector of the Venezuelan economy, following a determination by the Secretary…
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