Category: The PT Law Blog

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Proposal Would Require Political Donation Disclosure by Public Companies

This proposal could impact the business and operations of public companies and, some argue, could discourage corporate and individual participation in the political process. The Committee’s proposal would not apply to privately held companies. If this petition develops into a proposed rule, a public comment period and opportunities for stakeholders to share their concerns for the proposed rule will be provided as the SEC considers the petition.

The Congress may look in to this matter during the upcoming fall session. It is worth noting that publicly held companies are allowed to make political contributions in twenty-eight (28) states.

We suggest that interested companies and individuals remain aware of the developments with regard to this issue. If you would like further information or advice specific to your business, please contact us. Please follow this link to download a copy of the Committee’s petition.

 

 

 

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US Government Issues Cuba Travel Advisory

Poblete Tamargo analysts have noted an increase number of U.S. and foreign-based companies offering Cuba travel packages to persons living in the United States. We believe that some of these companies are making offers that appear to be outside the bounds set by the U.S. government for sponsored and educational travel to the island. In the process, they may be exposing customers to legal liablity. 

Tourism and tourism-like travel is not allowed for any persons travelling to Cuba, including U.S. persons with family on the island. People who are authorized to travel to Cuba remain subject to daily spending limits and are prohibited from bringing any Cuban “souvenirs” or other goods into the United States, with the exception of information and informational materials.

Civil and criminal penalties remain in place for violations of the Cuba sanctions regulations. 

The OFAC Advisory is available for review, here. 

 

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U.S. Updates Export Control Entity List

The Entity List provides notice to the public that certain exports, reexports, and transfers (in-country) to entities identified on the Entity List require a license from BIS and that the availability of license exceptions in such transactions is limited.

The Federal Register notice on this update is available here.

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Obama Administration Announces New Strategy to Combat Transnational Crime

Of particular interest, an Executive Order will establish a new economic sanctions program to “block the property of and prohibit transactions with significant transnational criminal networks that threaten national security, foreign policy, or economic interests.”

This announcement will be of interest to companies engaged in international trade as we as financial institutions located throughout the world. There is also a Foreign Corrupt Practices Act component. The White House report is available for download here.

We will be sending to our clients a detailed analysis of this new strategy. It will summarize how it will impact their compliance and other business considerations. Please contact us if you are interested in learning more about this or how we can assist your company with your federal regulatory or business needs.