Careers

Diversity, Equity & Inclusion

Experience

Innovation

Interactive Maps

Locations

About

Pages

Meet our team of innovators
Ask us how we do it

Professionals

Insights

Services

Thompson Hine LLP, a full-service business law firm with approximately 400 lawyers in 11 offices, was ranked number 1 in the category “Most innovative North American law firms: New working models” by The Financial Times and was 1 of 7 firms shortlisted for The American Lawyer’s inaugural Legal Services Innovation Award. The firm has been recognized by the National Law Journal as a Legal Technology Trailblazer and featured by Bloomberg for its innovative service delivery models, which drive accuracy and predictability. The firm’s commitment to innovation is embodied in Thompson Hine SmartPaTHTM – a smarter way to work – predictable, efficient and aligned with client goals. For more information, please visit ThompsonHine.com and ThompsonHine.com/SmartPaTH.

Home | Thompson Hine LLP

Atlanta

Chicago

Cincinnati

Cleveland

Columbus

Dayton

Los Angeles

Minneapolis

New York

Silicon Valley

Washington, D.C.

In a series of actions on April 17, the Trump administration announced the implementation of additional sanctions on the &ldquo;Troika of Tyranny&rdquo; in the Western Hemisphere (see <a href="https://www.trumpandtrade.com/2018/11/additional-cuban-companies-sanctioned-united-states/">Trump and Trade Update of November 16, 2018</a>). President Donald J. Trump and his National Security Advisor John Bolton have long held that Cuba, Venezuela and Nicaragua are the cause of great human suffering and the impetus of enormous regional instability, and have increasingly focused the administration&rsquo;s attention on these three countries. In announcing these additional sanctions, Trump said in a brief <a href="https://trumpwhitehouse.archives.gov/briefings-statements/president-donald-j-trump-taking-stand-democracy-human-rights-western-hemisphere/" target="_blank" rel="noopener">press statement</a> that &ldquo;When Venezuela is free, and Cuba is free, and Nicaragua is free, this will become the first free hemisphere in all of human history.&rdquo;
In <a href="https://www.state.gov/secretary/remarks/2019/04/291174.htm" target="_blank" rel="noopener">remarks to the press</a>, Secretary of State Mike Pompeo announced that under Title III of the Cuban Liberty and Democratic Solidarity Act (also known as Libertad), U.S. citizens who had their property confiscated by the Castro regime will now be able to file suit against those who traffic in such properties, effective May 2, 2019. While this provision of Libertad has been in place since 1996, all previous presidential administrations had suspended this provision. Pompeo stated that &ldquo;Implementing Title III in full means a chance at justice for Cuban Americans who have long sought relief for Fidel Castro and his lackeys seizing property without compensation. For the first time, claimants will be able to bring lawsuits against persons trafficking in property that was confiscated by the Cuban regime. Any person or company doing business in Cuba should heed this announcement.&rdquo; He further advised that companies doing business in Cuba investigate whether they are connected &ldquo;to property stolen in service of a failed communist experiment.&rdquo; Assistant Secretary for Western Hemisphere Affairs Kimberly Breier <a href="https://www.state.gov/r/pa/prs/ps/2019/04/291176.htm" target="_blank" rel="noopener">took questions</a> during this State Department briefing, which focused on the concerns of European and Canadian companies that could be affected by any such lawsuits. Canada and the European Union released a <a href="http://europa.eu/rapid/press-release_STATEMENT-19-2171_en.htm" target="_blank" rel="noopener">joint statement</a> noting their &ldquo;strong opposition to the extraterritorial application of unilateral Cuba-related measures that are contrary to international law.&rdquo;
National Security Advisor Bolton noted in a <a href="https://www.pbs.org/newshour/politics/watch-live-bolton-to-address-trump-administrations-cuba-policy-shift" target="_blank" rel="noopener">speech</a> that the United States would also be re-imposing limits on the amounts of money that Cuban Americans can send to relatives on the island, as well as the frequency of transactions, and ordering new restrictions on travel to Cuba by U.S. citizens.
Regarding Venezuela, the Department of the Treasury&rsquo;s Office of Foreign Assets Control (OFAC) <a href="https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pages/20190417.aspx" target="_blank" rel="noopener">placed the Banco Central de Venezuela</a> (i.e., the Central Bank of Venezuela) on the Specially Designated Nationals (SDN) List, for operating in the financial sector of the Venezuelan economy. Treasury Secretary Steven Mnuchin stated that this action was being taken in order &ldquo;to prevent it from being used as a tool of the illegitimate Maduro regime, which continues to plunder Venezuelan assets and exploit government institutions to enrich corrupt insiders.&rdquo; As a result of this action, all property and interests in property of the bank, and any entity that is owned, directly or indirectly, 50 percent or more by the bank that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. Further, OFAC&rsquo;s regulations generally prohibit all dealings by U.S. persons that involve the Central Bank of Venezuela. OFAC did note that it has issued amendments to current Venezuela-related general licenses and issued new general licenses, &ldquo;which include authorizations to ensure that U.S. persons may continue to engage in and facilitate non-commercial, personal remittances and the provision of humanitarian assistance to the people of Venezuela.&rdquo;
Rounding out the Trump administration&rsquo;s tightening of sanctions on the &ldquo;Troika of Tyranny,&rdquo; OFAC also placed Laureano Ortega Murillo, the son of Nicaraguan President Daniel Ortega and Vice President Rosario Murillo, on the SDN List, <a href="https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pages/20190417.aspx" target="_blank" rel="noopener">as well as Nicaraguan bank Banco Corporativo SA</a> (BanCorp). Sigal Mandelker, Under Secretary of the Treasury for Terrorism and Financial Intelligence stated that, &ldquo;Treasury is sanctioning Laureano Ortega Murillo and BanCorp for their roles in corruption and money laundering for the personal gain of the Ortega regime.&rdquo;

core/freeform

SmarTrade

Trump Administration Implements Further Sanctions Against Cuba, Venezuela and Nicaragua