Log in or register
Share on LinkedInShare on LinkedIn

ARTICLE · 27 APRIL 2016

Recent Comments From OFAC Regarding Cuba-Related Sanctions

Duane Morris LLP
Duane Morris LLP
Contributor
Explore more from Duane Morris LLP

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 Cuba and this Alert highlights key aspects of this guidance.

United StatesInternational Law
Brian Goldstein
Brian Goldstein
Author LinkedIn connections

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 Cuba and this Alert highlights key aspects of this guidance. Section 515.584(d) of the Cuban Assets Control Regulations (CACR) permits so-called "U-turn" transactions to originate at foreign branches and subsidiaries of U.S. banking institutions. Thus, U.S. banking institutions are permitted to process funds transfers originating and terminating outside the United States as long as neither the originator nor the beneficiary is a person subject to U.S. jurisdiction. Please refer to the general license set forth in Section 515.584(d).

Nevertheless, OFAC expects U.S. banking institutions to exercise due diligence relating to these U-turn transactions "on their own direct customers," including ownership structure, proof of citizenship (for individuals) and address information, to confirm that the transactions are consistent

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

View source

Related Articles

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

See more popular content from

Article

The Lindsey Graham Sanctions Act: What Businesses Need To Know About The New Tariffs

President Trump signed the Lindsey O. Graham Sanctioning Russia and Iran Act into law on September 18, 2026, establishing mandatory tariffs of up to 500% on Russian goods and up to 100% on goods from countries that continue to buy Russian energy. The Act targets major importers like China, India, and Turkey, with limited relief mechanisms including natural gas exceptions, presidential waivers, and a 270-day winddown period for entities divesting from Russian operations.
GlobalInternational Law
Crowell & Moring LLP
Crowell & Moring LLP
Article

Updates On Export Controls Impacting AI & Advanced Computing

The U.S. Department of Commerce's Bureau of Industry and Security issued guidance on May 31, 2026, clarifying licensing requirements for advanced computing items and AI technologies. The guidance maintains export restrictions for entities in certain countries while providing limited relief for data center operators, though questions remain about future regulatory direction. Companies must now strengthen their compliance programs and supply-chain due diligence as BIS continues to prioritize national security
GlobalInternational Law
Finnegan, Henderson, Farabow, Garrett & Dunner LLP
Finnegan, Henderson, Farabow, Garrett & Dunner LLP
Article

New Tariffs And Import Bans: An Update On The U.S.-Canada “Trade War”

The U.S.-Canada trading relationship has reached a critical juncture as both nations implement escalating trade measures, with Canada's counter-tariffs taking effect and the United States responding with unprecedented import bans on Canadian alcoholic beverages, dairy products, and motorcycles. These actions mark a significant expansion of the Trump Administration's use of Section 338 of the Tariff Act of 1930, moving beyond additional tariffs to outright import restrictions. What does this escalation mean
GlobalInternational Law
Cassidy Levy Kent LLP
Cassidy Levy Kent LLP
Article

Update On CAPE Phase 3 Duty Refunds From U.S. Customs And Border Protection

U.S. Customs and Border Protection has announced that importers with court orders for IEEPA duty refunds on finally liquidated entries can begin filing for those refunds starting October 6, 2026, through the CAPE Phase 3 system. This development follows the Supreme Court's February 2026 decision striking down IEEPA tariffs and represents a critical step for importers seeking refunds on entries liquidated for more than 80 days.
United StatesInternational Law
Buchanan Ingersoll & Rooney
Buchanan Ingersoll & Rooney
Article

Congress Passes New Russian Sanctions Bill Providing Additional Tariff Authority To Address Countries That Purchase Russian Energy, Facilitate Evasion Of Russian Sanctions

The U.S. House of Representatives has passed H.R. 5334, the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026, which directs the President to impose tariffs of up to 500 percent on Russian imports and up to 100 percent on imports from countries that are significant purchasers of Russian energy. The bill includes provisions for Presidential waiver authority and a five-year sunset clause...
GlobalInternational Law
Kelley Drye & Warren LLP
Kelley Drye & Warren LLP
Article

DHS Proposes $70,000 And $30,000 Fees For F-1 Optional Practical Training

The Department of Homeland Security has proposed a controversial new rule requiring SEVP-certified schools to pay substantial fees—$70,000 for a student's first Optional Practical Training recommendation and $30,000 for each subsequent OPT application, including STEM extensions. With only a 30-day comment period and potential annual costs reaching up to $16.5 billion across nearly 2,500 affected institutions, the proposed regulation is expected to face significant legal challenges if finalized.
United StatesImmigration
Duane Morris LLP
Duane Morris LLP
Article

SEC Proposes Rule Amendments To Expand Retail Access To Private Markets

The SEC has proposed sweeping amendments to expand retail investor access to private market strategies, including changes to performance-based compensation rules for registered investment advisers and modernization of the interval fund framework. The proposals also explore new credential-based pathways for individuals to qualify as accredited investors, potentially opening private offerings to a broader pool of eligible participants.
United StatesFinance and Banking
Duane Morris LLP
Duane Morris LLP
Video

The Class Action Weekly Wire – Episode 168: Maryland Federal Court Dismisses ‘Drip Pricing’ Class Action Against Ticket Reseller (Video)

A federal court in Maryland recently ruled on a consumer protection class action against Vivid Seats involving allegations of "drip pricing" - the practice of advertising ticket prices without mandatory fees that are revealed later in checkout. While the court found the company's arbitration agreement unenforceable due to its unilateral modification clause, it ultimately dismissed the lawsuit for failure to adequately allege reliance or injury under Maryland's Consumer Protection Act.
United StatesConsumer Protection
Duane Morris LLP
Duane Morris LLP