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New Economic Opportunities with Cuba Present Financial Rewards Along with Associated Compliance Challenges
  • Pepper Hamilton LLP
  • Cuba, USA
  • May 23 2016

The opening of Cuba to greater commercial and financial activity offers many possibilities for U.S. financial institutions but, with those


Banks Caught Between Scylla (OFAC) and Charybdis (Customer Wrath)
  • Bryan Cave LLP
  • Cuba, USA
  • May 4 2016

By now, we've all seen these stories. A slightly dimwitted, possibly drunk, prankster writes "I ISIS" in the memo line of a check or in the


OFAC Updates Cuba-Related FAQ Document
  • Cozen O'Connor
  • Cuba, USA
  • May 3 2016

On April 21, 2016, The Department of Treasury’s Office of Foreign Assets Control (OFAC) updated its FAQ document related to Cuba. This document


OFAC updates Cuba-related frequently asked questions
  • BuckleySandler LLP
  • Cuba, USA
  • April 29 2016

On April 21, OFAC updated its list of frequently asked questions related to Cuba. The updated document includes eight new FAQs clarifying (i) that


Impressions from a Return Trip to Havana
  • Haynes and Boone LLP
  • Cuba, USA
  • April 29 2016

Having returned recently from a six-day “people to people” trip to Havana arranged through the State Bar of Texas, I am struck by a variety of


Two Heads Are Not Always Better Than One
  • Bryan Cave LLP
  • Cuba, USA
  • April 28 2016

The Office of Foreign Assets Control (“OFAC”) last week updated its Cuba FAQs with this perplexing little blurb that can only charitably actually be


Recent Comments from OFAC Regarding Cuba-Related Sanctions
  • Duane Morris LLP
  • Cuba, USA
  • April 26 2016

On April 21, 2016, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) updated its Frequently Asked Questions Related to


Despite Recently Announced Reform, Cuban Government Signals Continuing Reforms “Without Haste But Without Pause”
  • Hunton & Williams LLP
  • Cuba, USA
  • April 26 2016

After President Obama on December 17, 2014, announced a policy change designed to engage and empower the Cuban people, Carnival Corporation


New OFAC FAQs for Cuba Clarify U-Turn Funds Transfers, Insurance, Re-Imports and Third Country Trade
  • Steptoe & Johnson LLP
  • Cuba, USA
  • April 26 2016

On April 21, 2016, the Treasury Department's Office of Foreign Assets Control ("OFAC") published eight new FAQs on its Cuba sanctions program. OFAC


OFAC Provides Helpful New Guidance for Cuba
  • Pillsbury Winthrop Shaw Pittman LLP
  • Cuba, USA
  • April 25 2016

The Office of Foreign Assets Control (OFAC) updated its FAQs for Cuba on April 21, 2016 with substantive guidance that addresses U-turn transactions