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Trade Security

The Odebrecht Contagion

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Tuesday, 11 July 2017 15:25

By: Jason I. Poblete

The following article, written by PobleteTamargo attorney Jason Poblete, was published in the Trade Security Journal’s July 2017 Issue. 


It is the scandal that rocked continents. Jason Poblete examines the Odebrecht case, a story of corruption in the $ billions and asks what lessons can be learned for business around the world.

Read more... [The Odebrecht Contagion]

What is Your Company's Foreign Policy

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By: Arthur M. Freyre

Company Foreign Policy Banner

During the mid-2000’s the city of Miami, as well as the United States as a whole, suffered one of the worst recessions since World War II. The downshift in economic growth was in part due to the foreclosures of many commercial and residential properties across the nation. In Miami-Dade, however the annual rate of growth for the economy was 3.5% from 2001 through 2005[1], much higher than the 2.8% across the nation. One of the major contributing elements to the regions economic growth came from the international trade sector, which grew from $65.9 billion in 2005 to $106.85 billion in 2015[2].

During that time, the international trade sector proved to be a vital component to the growth of the economy. One of many factors that fueled such positive growth was the number of small businesses that expanded into the international market.

Read more... [What is Your Company's Foreign Policy]

CLIENT ALERT — United States Government Publishes A List of Goods and Services that May Be Imported to the United States from Cuban “Cuentapropistas”

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Trade Security
Friday, 13 February 2015 11:51

CLIENT ALERT — United States Government Publishes A List of Goods and Services that May Be Imported to the United States from Cuban “Cuentapropistas”

Special Compliance Challenges in Store for Persons Subject to U.S. Law

By Jason I. Poblete

(Washington, DC) On Friday, February 13 the State Department released additional new regulations designed to create “new opportunities for Cuba’s nascent private sector” by allowing the import to the United States of products and services from Cubans not working directly for the government or a government agency. The import list addition to the Cuban Assets Control Regulations (“CACR”), 31 C.F.R. § 515 come less than a month after the Treasury and Commerce Departments issued new regulations on January 16 that made it easier for Americans to travel and spend money in Cuba. 

Read more... [CLIENT ALERT — United States Government Publishes A List of Goods and Services that May Be Imported to the United States from Cuban “Cuentapropistas”]

Compliance and Economic Sanctions in the Virtual Arena, Workable and Never Ending

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Trade Security
Thursday, 30 January 2014 12:13

By Jason I. Poblete

The majority of U.S. economic sanctions laws and regulations designed for the brick and mortar world, continue to present compliance challenges for businesses offering goods and services on the web. The Internet makes it easier to get around and avoid sanctions, and export controls, but compliance remains necessary.

The brick and mortar rules, at a certain level, are almost impossible to enforce in the virtual world. Foreigners can use a variety of tools such to mask identity and place. Take this to the bank, the bad actors always find a way to break the law. This presents many challenges for companies with just about any sort of U.S. nexus.

Read more... [Compliance and Economic Sanctions in the Virtual Arena, Workable and Never Ending]

WSJ: US Sues Over Magnitsky Scandal-Linked Assets

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Trade Security
Wednesday, 11 September 2013 15:40

Today's Wall Street Journal reports that "[p]rosecutors filed a civil complaint seeking the assets of 11 companies linked to a $230 million Russian tax-refund fraud uncovered by deceased Russian lawyer Sergei Magnitsky." Read the entire story here.

Read more... [WSJ: US Sues Over Magnitsky Scandal-Linked Assets]

On the books for some time: National Emergency With Respect to Syria

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Trade Security
Monday, 09 September 2013 10:33

Jason I. Poblete

syria pol 2007Whenever the United States announces that it may engage in foreign military activities, a discussion invariably ensues in this town regarding the use of economic sanctions. Opponents of military action tend to urge more aggressive use of them, while sanctions detractors will argue that they do not work. The current national debate as to whether or not to use military force in Syria to punish the Syrian government for the alleged use of chemical weapons is a good example of this back and forth. 

Economic sanctions are tools, not a policy. They can be part of a clearly articulated foreign policy, without it, they are not very effective. It should also go without saying, in order to yield results sanctions need to be robustly enforced, usually over a prolonged period of time. Once the target nation or person has committed an offending action, if allowed to continue to do so, economic sanctions tend to do little to deter the offending acitivities in the future.

Read more... [On the books for some time: National Emergency With Respect to Syria]

UAE Company Fined for Violating U.S.-Syria Sanctions, Export Control Laws

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Trade Security
Wednesday, 01 May 2013 10:53

Jason I. Poblete

Computerlinks, a UAE-based company that sells information technology product and services, has been fined $2.8 million for violating U.S.-Syria export control laws. According to the Department of Commerce Bureau of Industry and Security (BIS), Computerlinks committed three violations of the Export Administration Regulations (the Regulations) by engaging in transactions or taking:

Read more... [UAE Company Fined for Violating U.S.-Syria Sanctions, Export Control Laws]

US State Department: Terrorist Designations of Ansar al-Dine

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Trade Security
Friday, 22 March 2013 09:29

Pursuant to Section 219 of the Immigration and Nationality Act and under Executive Order (E.O.) 13224, the U.S. Department of State has designated Ansar al-Dine (AAD) a Foreign Terrorist Organization (FTO). According to the State Department:

"AAD has received support from AQIM since its inception in late 2011, and continues to maintain close ties to the group. AAD has received backing from AQIM in its fight against Malian and French forces, most notably in the capture of the Malian towns of Agulhok, Tessalit, Kidal, Gao, and Timbuktu, between January and April 2012."

Read more... [US State Department: Terrorist Designations of Ansar al-Dine]

Vegas Casino Corp. Deftly Refutes Allegations of Foreign Corruption

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Trade Security
Thursday, 07 March 2013 00:00

Jason I. Poblete

When senior company officials are politically active, or the company has matters pending before the U.S. Congress or federal agencies, your legal and public policy departments have to deal with a whole set of potential issues that other companies do not, at least not with the same intensity. Last week, several newspapers posted a story about the owner of the Las Vegas Sands corporation that is illustrative of what can happen when the law and public policy worlds collide; and also shows how a company should respond. 

The story deals with a very potentially serious legal issue faced by companies that do business around the world, compliance with the Foreign Corrupt Practices Act, or FCPA for short. The Las Vegas Sands corporation reported in its annual shareholders report that that company personnel may have violated the books, records, and internal control provisions of this anti-corruption law.

Read more... [Vegas Casino Corp. Deftly Refutes Allegations of Foreign Corruption]

OFAC Hosts Financial Services Industry Symposium

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Trade Security
Thursday, 21 February 2013 14:53

Jason Poblete

The Treasury Department’s Office of Foreign Assets Control (OFAC) will host a Financial Services Industry Symposium in Washington, DC on March 19, 2013. Expected topics on the agenda include:

  1. Review of recent changes to Iran sanctions
  2. Overview of recent enforcement actions and guidelines
  3. Licensing procedures and guidance
  4. Compliance with U.S. economic and trade sanctions


These conferences are a good opportunity to meet with OFAC personnel and answer questions about general matters of interest to your companies. 

For more information visit this OFAC website or contact us.

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