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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

BIS Issues Export Guidance to ‎Academia

On August 14, 2024, the U.S. Department of Commerce's Bureau of Industry and Security (“BIS”) issued guidance to the U.S. academic community regarding compliance with export controls and to protect U.S. national security....more

OFAC Issues General Licenses, Updates FAQ, and Issues New Blocking Rule and Reminder to File Annual Blocked Property Report

On September 5, 2024, the Department of the Treasury's Office of Foreign Assets Control (“OFAC”) released General License (“GL”) 108 (“Authorizing Limited Safety and Environmental Transactions Involving Certain Blocked...more

OFAC Amends Cuban Assets Control Regulations and Issues New FAQs for U-Turn Transactions

On August 27, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced amendments to two key FAQs (FAQs 736 and 757) concerning the Cuban Assets Control Regulations (“CACR”). These FAQs...more

U.S. Anti-Boycott Pitfalls

In a recent enforcement action, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) imposed a civil penalty on a U.S. company for violations of the antiboycott provisions under Part 760 of the Export...more

BIS Issues New FDP Restrictions on Goods Destined for Iran

On April 24, 2024, President Biden signed into law the "Making Emergency Supplemental Appropriations for the Fiscal Year Ending September 30, 2024, and for Other Purposes" Act. This law mandates that the United States...more

What Do Diamonds, Safety and the Environment Have in Common? OFAC New General Licenses and FAQs

On August 23, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License (“GL”) 103 ("Authorizing Transactions Related to Imports of Certain Diamond Jewelry Prohibited by...more

FinCEN Proposes AML/CFT ‎Augmentation Rule

On June 28, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a Notice of Proposed Rulemaking (“NPRM”) intended to strengthen and modernize U.S. financial institutions’...more

BIS Tightens Export Controls on Russia ‎and Belarus

On August 23, 2024, the U.S. Department of Commerce's Bureau of Industry and Security (“BIS”) announced a series of new measures to further restrict the supply of U.S.-origin and "U.S.-branded" items to Russia and Belarus...more

OFAC Extends and Issues General Licenses Involving Russian Tax and Civil Aviation Safety

The U.S. Department of the Treasury’s Office of Foreign Asset Control ‎‎(“OFAC”) on (i) July 10, 2024, extended General License (“GL”) 13J (“Authorizing Certain Administrative Transactions Prohibited by Directive 4 under...more

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