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Sanction Violations Economic Sanctions

Locke Lord LLP

Price Cap Coalition Issues Advisory ‎Regarding Sanctions Evasion Techniques by the Shadow ‎Fleet

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On October 21, 2024, the Price Cap Coalition—comprising the G7, European Union, Australia, and New Zealand—released an updated advisory to address the rising risks of price cap evasion associated with the maritime oil trade,...more

Pillsbury Winthrop Shaw Pittman LLP

New UK Trade Sanctions Enforcement Body Goes Live October 10, 2024

New UK enforcement body goes live and new powers granted to existing body, regulating those doing business in the UK. UK trade sanctions enforcement risks are set to increase on October 10, 2024, as two government agencies...more

The Volkov Law Group

UK’s OFSI Imposes £15,000 Penalty on Property Management Company for Sanctions Violations

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In late August 2024, the UK’s Office of Financial Sanctions Implementation (“OFSI”), a department within HM Treasury, imposed a monetary penalty of £15,000 on Integral Concierge Services Limited (“ICSL”)—a UK-based property...more

McDermott Will & Emery

Quarterly Sanctions Update | Q3 2024

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Although the European Union and the United Kingdom did not introduce new sanctions against Russia over the summer, they extensively focused on the implementation of the existing measures and their enforcement. This week,...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

Locke Lord LLP

OFAC Takes Action Against Russian ‎Political Disinformation and ‎New Sanctions Evasion Tactics

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Russian Political Disinformation Efforts - On September 4, 2024, the U.S. Department of the Treasury's Office of Foreign Assets Control (“OFAC”) designated 10 individuals and two entities as specially designated nationals...more

Ankura

Russian Sanctions Circumvention: Are You Asleep At The Wheel?

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In the wake of Russia's invasion of Ukraine in February 2022, a broad and unprecedented range of sanctions were imposed on Russia by various countries and international bodies to target the Russian economy and prevent further...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

Hogan Lovells

UK makes trade sanctions violation a strict liability offence and amends the legal advisory services ban

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Significant legislative changes have been made to the UK’s sanctions regime in the first half of September 2024, namely: These new amendments demonstrate the UK’s further efforts in imposing penalties against sanctions...more

The Volkov Law Group

State Street’s $7.45MM OFAC Penalty Highlights Importance of Sanctions in M&A Due Diligence

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has released a $7.45 million penalty against State Street Bank and Trust Company and its non-bank, fintech subsidiary Charles River Systems for...more

Blank Rome LLP

OFAC Guidance on Extending the Statute of Limitations for Sanctions Violations Signals Aggressive Enforcement

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) last week issued guidance regarding the extension of the statute of limitations for sanctions violations. This guidance follows the enactment of...more

Faegre Drinker Biddle & Reath LLP

New (and Extended) Statute of Limitations for Many Sanctions Violations Enforced by OFAC

New OFAC Guidance on Statute of Limitations - On July 22, 2024, the Office of Foreign Assets Control (OFAC) published new guidance addressing how it intends to apply a recent change in the statute of limitations for...more

Hogan Lovells

OFAC issues statute of limitations guidance for US sanctions violations and recordkeeping

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The US Department of the Treasury’s Office of Foreign Assets Control has released guidance following on Congress’ extension of the statute of limitations for violations of certain sanctions and related recordkeeping...more

Katten Muchin Rosenman LLP

OFAC Announces Forthcoming Expanded Recordkeeping Rule

On July 22, 2024, the Office of Foreign Assets Control ("OFAC") of the U.S. Department of the Treasury issued a Guidance on Extension of Statute of Limitations (the "Guidance"). The Guidance calls attention to the recently...more

The Volkov Law Group

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

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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

Fenwick & West LLP

OFAC Publishes Guidance on 10-Year Sanctions Violations Statute of Limitations

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On July 22, 2024, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) issued guidance addressing the April 2024 extension of the statute of limitations for sanctions violations from five years to 10...more

Ankura

Navigating OFAC Sanctions Risks in the Digital Realm: IP Addresses and Effective Controls

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In today's digital landscape, sanctions enforcement has become a critical concern for Financial Institutions (FIs). The borderless nature of cyberspace can make it difficult to monitor and regulate activities that may breach...more

McGuireWoods LLP

OFAC Enforcement Action Targets Non-U.S. Business Purchasing Services From North Korean Firm

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On June 26, Treasury’s Office of Foreign Assets Control (OFAC) announced the settlement of an enforcement action against an Italian animation company that violated OFAC’s sanctions on North Korea. The enforcement action...more

Locke Lord LLP

OFAC Doubles Statute of Limitations ‎for Sanctions Violations

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On April 24, 2024, President Biden signed into law H.R. 815 (Pub. L. 118-50), “Making emergency supplemental appropriations for the fiscal year ending September 30, 2024, and for other purposes” (the “Act”), which includes...more

The Volkov Law Group

Sanctions Enforcement on the Outer Edges of Trade Activity (Part II of II)

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We all know what a “core” sanctions violation looks like.  The heartland of such misconduct has been described on numerous occasions in OFAC enforcement actions and settlements.  In this environment, however, companies have...more

The Volkov Law Group

Sanctions Compliance: Understanding the Red Lines of Enforcement (Part I of II)

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In this new era of aggressive sanctions enforcement, companies have to understand the red lines that define where criminal and civil enforcement risk increase.  In contrast to the history of FCPA enforcement, DOJ and OFAC...more

Braumiller Law Group, PLLC

Braumiller-Law-Group - June 2024 Newletter

Recently, President Biden signed a foreign military support bill (H.R. 815) into law, which also encompassed the 21st Century Peace Through Strength Act (the Act), a legislative proposal introduced in the House containing...more

Braumiller Law Group, PLLC

Hot Topics in International Trade - June 2024 - New Legislation Extends Statute of Limitations for Sanctions Violations

Recently, President Biden signed a foreign military support bill (H.R. 815) into law, which also encompassed the 21st Century Peace Through Strength Act (the Act), a legislative proposal introduced in the House containing...more

BCLP

Adoption of Directive (Ue) 2024/1226 on Criminalisation of Violations of EU Sanctions: What Are the Stakes Involved in Transposing...

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On 19 May, Directive (EU) 2024/1226 on the definition of criminal offences and sanctions for breaches of EU restrictive measures, adopted by the EU Council on 24 April, entered into force. By harmonizing the laws of the...more

Latham & Watkins LLP

Sanctions Update: EU Takes Step to Harmonise Criminal Penalties for Breaches of EU Sanctions

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The new Directive (EU) 2024/1226 defines criminal offences and penalties for breaches of EU sanctions. This Client Alert summarises key provisions and implications for businesses. This Client Alert is published in the...more

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