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OFAC Takes Further Action Against ‎Maduro-Aligned Officials ‎Following Venezuelan Election ‎Malfeasance

On November 27, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) sanctioned 21 high-ranking Venezuelan officials aligned with Nicolás Maduro. These sanctions, issued under Executive Order...more

BIS Strengthens Export Controls on ‎China’s Advanced Technology Capabilities

On December 2, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) announced two interim final rules (collectively, the “December 2024 Rules”) (“Foreign-Produced Direct Product Rule Additions, and...more

BIS Highlights Risks in “Legacy” ‎Semiconductor Supply Chains

On December 6, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) released a report (the “Report”) highlighting significant risks associated with the use of mature-node semiconductor chips, also...more

Between a Claim and a Hard Place: OFAC Sanctions Preempt State Insurance Laws

U.S. sanctions laws present complex conflicts with state insurance laws. While state laws govern the timely payment of claims and other insurance practices, U.S. sanctions administered by the U.S. Department of the Treasury’s...more

OFAC Updates General Licenses and ‎FAQ on PdVSA 2020 8.5% ‎Bonds

On November 7, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License (“GL”) 5Q ("Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5...more

OFAC Sanctions the Russian Financial ‎Sector Including ‎Gazprombank, and Issues New GLs and FAQs

On November 21, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated Gazprombank, over 50 internationally connected Russian banks, more than 40 Russian securities registrars, and 15...more

FUNDamentals: 2025 SEC Examination ‎Priorities

On October 21, 2024, the U.S. Securities and Exchange Commission’s (“SEC”) Division of Examinations (the “Division”) released its examination priorities for 2025 (the “2025 SEC Examination Priorities”). The Division will...more

Final Rule Issued Regarding U.S. ‎Outbound Investments in ‎Certain Chinese National Security ‎Technologies and Products

On October 28, 2024, the U.S. Department of the Treasury (the “Treasury”) released final regulations (the “Final Rule”) to implement Executive Order 14105, titled “Addressing United States Investments in Certain National...more

OFAC Issues New and Amended FAQs ‎for the Insurance ‎Industry

On November 13, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) amended several insurance-related Frequently Asked Questions (“FAQs”) (61, 62, 63, 64, 65, 68, 69, 102, 103, and 104) as...more

OFAC Issues New Guidance to Maritime Industry Stakeholders and Insurers to Focus on Rising Sanctions Evasion Tactics

On October 31, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) released guidance to the maritime shipping industry to help stakeholders identify and avoid sanctions evasion tactics. The...more

OFAC Issues Russia Sanctions General ‎Licenses and FAQs ‎Related to Securities Held at the National ‎Settlement Depository

On October 10, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued Frequently Asked Question (“FAQ”) 1197 on securities held at the National Settlement Depository (“NSD”) in connection...more

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

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

BIS Issues New Guidance to Financial ‎Institutions on Best ‎Practices for Compliance With ‎the EAR

On October 9, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued its first-ever guidance to financial institutions (“FIs”) on best practices to comply with the Export Administration...more

Key Takeaways for Antiboycott Compliance Programs Following BIS Penalizing Company for Antiboycott Violations

On September 30, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) imposed a civil penalty of $151,875 against a U.S.-based technology company to resolve 45 alleged violations of the antiboycott...more

OFAC’s Extended Recordkeeping Requirements From 5 to 10 Years

On September 11, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued an Interim Final Rule amending its Reporting, Procedures, and Penalties Regulations under 31 C.F.R. Part 501. This...more

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

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

OFAC Issues FAQs for IT and Software ‎‎Services and Extends Authorization to Engage in ‎Administrative ‎Transactions in Russia

On September 24, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued three frequently asked questions (“FAQs”) that provide guidance to U.S. companies regarding the Determination...more

Guidelines for Preparing BIS Export ‎License Applications Involving Foreign Persons ‎‎(Deemed ‎Exports-Reexports)‎

On September 1, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) released new guidelines to support deemed export applicants in acquiring necessary licenses. While these guidelines are primarily...more

FUNDamentals: Navigating FinCEN’s ‎New AML Regulations for Investment ‎Advisers

On August 28, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a final rule (the “Rule”) that amends the definition of “financial institution” under the Bank Secrecy Act...more

BIS Proposes New Rule to Restrict ‎Connected Vehicles Linked to ‎Chinese or Russian Technology

On September 23, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) announced a proposed rule that could reshape the automotive industry by restricting the import and sale of connected vehicles....more

BIS Proposes New Reporting ‎Requirements for the Development ‎of Advanced AI Models & ‎Computing Clusters

On September 9, 2024, U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a Notice of Proposed Rule Making (“NRPM”), which would mandate new reporting requirements for artificial intelligence (“AI”)...more

New Export Controls on Advanced ‎Technologies: Quantum ‎Computing, Semiconductors, and ‎Additive Manufacturing

On September 6, 2024, the U.S. Department of Commerce's Bureau of Industry and Security (“BIS”) issued an interim final rule (the “Interim Rule”), aimed at strengthening export controls on advanced technologies, including...more

BIS Issues Key Updates to the ‎Voluntary Self-Disclosure Process ‎and Penalty Guidelines

On September 12, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule that requires reporting entities to make significant changes to Voluntary Self-Disclosures (“VSD”); the BIS...more

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

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

OFAC Issues Warning to Financial ‎Institutions & Insurers That ‎Provide Maritime Services in the ‎Mediterranean, Red Sea and...

Iran and Syria Sanctions and Embargos On September 11, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued updated guidance to remind maritime support service providers that the...more

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