News & Analysis as of

Office of Foreign Assets Control (OFAC) Export Controls

Benesch

Supply Chain Security Is National Security: Cyber, Physical, and Personnel Protections

Benesch on

U.S. supply chain security is increasingly under threat. The White House’s National Security Strategy describes this moment as an inflection point. Many federal agencies have taken charge in elevating the very concept of...more

K2 Integrity

First Ever Targeted Guidance On Financial Institutions’ Compliance With Export Administration Regulations

K2 Integrity on

On 9 October 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published its first ever unilateral guidance specifically addressed to financial institutions (FIs). The Guidance to Financial...more

Locke Lord LLP

OFAC Issues Global Magnitsky ‎Sanctions Relief for Ly Young Phat Group and FAQs

Locke Lord LLP on

On September 12, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License (“GL”) 8 alongside amendments to various Frequently Asked Questions (“FAQs”) in connection with the...more

Lowenstein Sandler LLP

Trade Matters - Lowenstein Sandler's Global Trade & National Security Newsletter - October 2024

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The U.S. Commerce Department is soliciting comments on a proposed rule to prohibit importing and selling Vehicle Connectivity System hardware and software designed, developed, manufactured, or supplied by persons owned by,...more

Mayer Brown

Russia/Ukraine Sanctions Update - Month of September

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I.  US SANCTIONS - U.S. Department of the Treasury Acts Against Russian Virtual Currency Exchanges: On September 26, the U.S. Department of the Treasury announced that its Financial Crimes Enforcement Network issued an...more

Adams and Reese LLP

International Compliance Digest - September 2024

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New export controls, new section 301 duties, new OFAC requirements, new de minimis rule, new DOJ corporate compliance guidance, new international guidance on Russian sanctions. September had it all....more

Buchalter

Expanded Export Controls and Sanctions Require Heightened Compliance for All Industries

Buchalter on

A Changed Regulatory Environment – Companies who think that U.S. export controls and sanctions do not apply to their products and channels of trade should reassess that position. As an example, approximately US$1.1 billion in...more

The Volkov Law Group

OFAC’s Stated Concern About Foreign Companies and Domestic Sanctions Compliance and Post-Acquisition Compliance (Party IV of IV)

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Foreign companies with U.S. operations are struggling to navigate the landscape of sanctions compliance. OFAC has expressed its concern that foreign companies need to deploy U.S. based expertise and resources to ensure...more

Torres Trade Law, PLLC

Application of the Substantial Transformation Principle in the Context of U.S. Sanctions

Torres Trade Law, PLLC on

The practice of determining an item’s country of origin (“COO”) and utilizing the principal of “substantial transformation” to help make this determination is likely a familiar concept for many U.S. importers in the context...more

American Conference Institute (ACI)

FCPA, Export Controls, and Sanctions Enforcement: Adjusting Compliance Strategies for the New Normal

As the interplay between export controls, trade sanctions, and anticorruption enforcement continues to intensify, multinational companies must remain vigilant in ensuring that their compliance programs address the many...more

The Volkov Law Group

The Four Sanctions Compliance Cases that Everyone Should Know (Part I of IV)

The Volkov Law Group on

The Justice Department has repeated on several occasions that it intends to aggressively prosecute corporations for sanctions and export controls violations. The “New FCPA” is how the Justice Department characterizes its...more

American Conference Institute (ACI)

Developments in Global Sanctions Compliance with a Focus on Russia, Belarus and China

Sanctions imposed by the United States, the United Kingdom, and the European Union against Russia, China, and other parts of the world are fast-evolving. Such geopolitical shifts are creating new risks and placing further...more

Lowenstein Sandler LLP

Trade Matters - Lowenstein Sandler's Global Trade & National Security Newsletter - September 19, 2024

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The Department of Commerce’s Bureau of Industry and Security (BIS) recently issued an interim final rule implementing licensing requirements for these emerging technology products for export to all foreign countries. See the...more

Morrison & Foerster LLP

OFAC Extends Recordkeeping Requirements from Five to 10 Years; Issues Paperwork Reduction Act Request for Comments

On September 11, 2024, OFAC announced its Interim Final Rule to Extend Recordkeeping Requirements from Five to 10 Years. The Interim Final Rule (IFR) was published in the Federal Register on September 13, 2024. Public...more

Dorsey & Whitney LLP

Biden Administration Again Expands Sanctions on Russia and Its Third Party Supporters

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As Russia continues its war against Ukraine and Ukraine has itself recently opened a new front by capturing Russian territory in its Kursk region, the United States announced on August 23 its latest tranche of sanctions...more

White & Case LLP

Sanctions move up the agenda for lenders and borrowers

White & Case LLP on

Compliance with sanctions regimes has been a priority for debt markets. Amid rising geopolitical tensions, the stakes for lenders and borrowers are higher than ever - Intensifying geopolitical tensions and the US...more

BakerHostetler

Current State of U.S. Economic Sanctions Imposed in Response to Russia’s Invasion of Ukraine - August 2024 #2

BakerHostetler on

In its continuing response to Russia’s invasion of Ukraine, the U.S. government has deployed a whole-of-government approach to impose sanctions and tighter export controls on Russia. This alert summarizes key economic...more

BakerHostetler

Current State of U.S. Export Controls in Response to the Russian Federation’s Invasion of Ukraine - August 2024

BakerHostetler on

In a continued effort to hinder Russia’s invasion of Ukraine, the U.S. government has deployed a whole-of-government approach to impose sanctions and tighter export controls on Russia. ...more

Kelley Drye & Warren LLP

Commerce, Treasury, and State Announce Measures Targeted at Further Restricting Russia and Belarus

On August 23, 2024, the U.S. Departments of Commerce, Treasury, and State published new restrictions on Russia aimed at further limiting its access to U.S. materials and international procurement networks for its military....more

BakerHostetler

Current State of U.S. Economic Sanctions Imposed in Response to Russia’s Invasion of Ukraine - August 2024

BakerHostetler on

In response to Russia’s invasion of Ukraine, the U.S. government has deployed a whole-of-government approach to impose sanctions and tighter export controls on Russia. This alert summarizes key economic sanctions imposed by...more

The Volkov Law Group

U.S. Sanctions Update as of April 2024

The Volkov Law Group on

U.S. Persons prohibited from transactions with anyone on the OFAC SDN List without a license, regardless of country. Includes entities owned in excess of 50-percent by one or more SDNs (33-percent for select Russian...more

Locke Lord LLP

OFAC Limits Exports of Technology to Russia ‎‎‎and Expands Secondary Sanctions on FFIs That Support ‎Russian War ‎Efforts

Locke Lord LLP on

On June 12, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a new Determination Pursuant to Section 1 (a)(ii) of Executive Order 14071 (the “Determination”)‎ that prohibits U.S....more

Lowenstein Sandler LLP

Trade Matters - Lowenstein Sandler's Global Trade & National Security Newsletter - August 2024

Lowenstein Sandler LLP on

The Bureau of Industry and Security (BIS) issued new guidance to prevent the diversion of controlled items to Russia. This guidance recommends the use of the Trade Integrity Project (TIP) database, which tracks suppliers with...more

Adams and Reese LLP

International Compliance Digest – July 2024

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July was a big month for compliance with a handful of reports and recommendations on due diligence and best practices concerning forced labor, export controls, sanctions from DHS, BIS, and OFAC. The below updates also...more

The Volkov Law Group

OFAC Releases Guidance on Extended Statute of Limitations & Forthcoming Recordkeeping Changes

The Volkov Law Group on

The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) has released updated guidance concerning recent legislation that doubled the statute of limitations for violations of certain sanctions and export control...more

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