November 2020
Newsletter
12 USMCA STRATEGIES YOU CAN’T IGNORE
We Revisit Practical Advice for NAFTA and how it applies to USMCA
It’s been a few months since USMCA officially became the new free trade agreement between the U.S., Canada, and Mexico. While we have seen a good number of companies jumping right in and adopting the new agreement, there may still be some out there that are waiting for January 1, 2021 thinking that maybe the 6 months in 2020 are just a trial or adoption period of some sort.
MORE APPARENT OFAC VIOLATIONS INVOLVING FOREIGN SUBSIDIARY COMPANIES
Parenting can be such a chore. Minding wayward little ones, cleaning up after them, and getting hit with six-figure Treasury Department penalties for their misbehavior can offset the joy of beholding the smiles on their cherubic faces.
Did I say Treasury Department penalties? Yes, they can arise when the parent is a U.S.-based company and the “child” is its foreign subsidiary, as documented in two recent penalty cases from Treasury’s Office of Foreign Assets Control. I doubt there were any smiles or cherubic faces involved in these family dramas.
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