The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) has published proposed amendments to the Export Administration Regulations (EAR) that would significantly expand the scope of the export controls over...more
8/9/2024
/ Anti-Terrorism Financing ,
Bureau of Industry and Security (BIS) ,
China ,
Directorate of Defense Trade Controls (DDTC) ,
Due Diligence ,
Export Administration Regulations (EAR) ,
Export Controls ,
Facial Recognition Technology ,
ITAR ,
Military End Use ,
National Intelligence Agencies ,
Popular ,
Proposed Amendments
Key Points - On May 10, 2024, OFAC issued an IFR that would amend its Reporting, Procedures and Penalties Regulations (RPPR) at 31 C.F.R. Part 501 to, among other things, modify certain reporting requirements pertaining to...more
Key Points - On April 17, 2024, based on a determination by the U.S. government that Nicolás Maduro and his representatives “have not fully met the commitments made” with respect to upcoming Venezuelan elections, the U.S....more
Key Points -
On January 16, 2024, Matthew Axelrod, Assistant Secretary for Export Enforcement at the U.S. Department of Commerce’s BIS announced key updates to BIS’s VSD process. The updates are also now reflected on BIS’s...more
1/26/2024
/ Bureau of Industry and Security (BIS) ,
Enforcement ,
Export Administration Regulations (EAR) ,
Exports ,
National Security ,
Negligence ,
Non-Prosecution Agreements ,
Penalties ,
Penalty Reductions ,
Self-Disclosure Requirements ,
U.S. Commerce Department ,
Voluntary Disclosure
Key Points -
On October 18, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) took action to relax certain U.S. sanctions on Venezuela in response to the signing of an electoral roadmap...more
Key Points -
On March 2, 2023, DOJ announced that its NSD would hire more than 25 new prosecutors to investigate and prosecute sanctions evasion, export controls violations and similar economic crimes. Consistent with...more
Introduction -
In 2022, the United States, European Union (EU) and United Kingdom, along with a significant number of other partners and allies, imposed an unprecedented number of economic, financial and trade sanctions...more
The volume and impact of changes to United States export control regulations in 2022 were unprecedented, and we expect 2023 will likely bring additional changes. This alert provides a summary of key changes, themes and...more
Background -
U.S. antiboycott laws, which are divided into two separate regimes administered by the U.S. Department of Commerce and the U.S. Department of the Treasury, prohibit U.S. persons from participating in foreign...more
Key Points -
BIS amended the EAR to add a new criterion for placing a party on the Entity List: a sustained lack of cooperation by the host government to schedule and facilitate the completion of an end-use check of an...more
Key Points -
As part of highly coordinated U.S. government and allied and partner country responses to Russia’s further invasion of Ukraine, and Belarus’ enabling of it, BIS imposed on February 24, 2022, and March 2,...more
Key Points -
The U.S. Department of Commerce has reorganized and clarified the regulations describing when foreign-produced items outside the United States are and are not subject to the licensing and other obligations of...more
Key Points -
The United States, European Union, United Kingdom and other U.S. allies are currently considering a range of severe economic measures against Russia to impose in the event of a Russian military incursion into...more
1/31/2022
/ Export Administration Regulations (EAR) ,
Export Controls ,
Financial Institutions ,
Foreign Policy ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Pipelines ,
Russia ,
Sanctions ,
SDN List ,
Ukraine
On September 21, 2021, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) published an updated sanctions advisory, providing guidance to companies on sanctions compliance obligations related to ransomware...more
12/14/2021
/ Compliance ,
Cryptocurrency ,
Cyber Attacks ,
Cybersecurity ,
Data Security ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
Ransomware ,
Sanctions ,
U.S. Treasury ,
Virtual Currency
On October 18, 2021, the U.S. Treasury Department released a long awaited report on its first of its kind “top to bottom” review of U.S. economic and financial sanctions. The report does not make or recommend any immediate or...more
On June 10, 2021, the 29th session of the Standing Committee of the 13th National People’s Congress ("NPC") adopted China’s new Anti-Foreign Sanctions Law,1which took immediate effect. The new law provides legal grounds for...more
Through updated guidance, the UAE has introduced a significant change to how it administers sanctions regimes—expanding its focus from a limited implementation of multilateral sanctions to more broadly imposing its own...more
As part of the United States’ response to Russia’s use of chemical weapons against Russian opposition figure Aleksey Navalny, the U.S. State Department applied a policy of denial to licenses and other approvals for exports to...more
On June 3, 2021, President Biden issued Executive Order 14032 (Addressing the Threat from Securities Investments that Finance Certain Companies of the People’s Republic of China) (“CMIC EO”) that modifies the Trump-era...more
Key Points -
On April 8, the Treasury Department removed the UAE from its list of countries requiring cooperation with an international boycott, thereby removing the UAE from the scope of the Treasury Department’s...more
In early October, the United States Department of Treasury’s Office of Foreign Assets Control (OFAC) issued an advisory, warning of the potential risk of sanctions to companies and individuals who pay ransomware payments. The...more
11/2/2020
/ Cyber Attacks ,
Cyber Crimes ,
Cyber Insurance ,
Cybersecurity ,
Economic Sanctions ,
Financial Institutions ,
Foreign Policy ,
Hackers ,
Office of Foreign Assets Control (OFAC) ,
Ransomware ,
Risk Management ,
Risk-Based Approaches ,
Sanction Violations
Whatever your business—whether you are a government entity in charge of mega projects, an oil and gas major responsible for energy security, an investor looking at new investments, managing existing positions or planning...more
Whatever your business—whether you are a government entity in charge of mega projects, an oil and gas major responsible for energy security, an investor looking at new investments, managing existing positions or planning...more
Whatever your business—whether you are a government entity in charge of mega projects, an oil and gas major responsible for energy security, an investor looking at new investments, managing existing positions or planning...more
Whatever your business—whether you are a government entity in charge of mega projects, an oil and gas major responsible for energy security, an investor looking at new investments, managing existing positions or planning...more