On April 24, 2024, President Biden signed into law H.R. 815, an emergency appropriations package billed as authorizing $95 billion in foreign aid to Ukraine and Israel (the Act). While the Ukraine and Israel aid provisions...more
4/30/2024
/ Appropriations Bill ,
Biden Administration ,
China ,
Economic Sanctions ,
EU ,
Export Controls ,
Exports ,
Federal Budget ,
FinCEN ,
Foreign Financial Institutions (FFI) ,
Israel ,
Russia ,
TikTok ,
UK ,
Ukraine
Companies faced with the decision of whether to voluntarily self-report sanctions breaches to law enforcement or sanctions enforcement agencies in the UK and the US can take some measure of comfort from recent comments made...more
10/16/2023
/ Compliance ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Good Faith ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Sanction Violations ,
Self-Reporting ,
Serious Fraud Office (SFO) ,
U.S. Commerce Department ,
U.S. Treasury ,
UK ,
Voluntary Disclosure
The Biden Administration has issued its long-awaited Executive Order on Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern (“EO”), which will create a new...more
8/11/2023
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Biden Administration ,
China ,
Cybersecurity ,
Executive Orders ,
Foreign Investment ,
NAICS ,
National Security ,
Outbound Transactions ,
Popular ,
Proposed Regulation ,
Supply Chain ,
Technology Sector ,
U.S. Treasury
The Committee on Foreign Investment in the United States (CFIUS) reviewed a record number of transactions for national security risks in 2022: 440 covered transactions, up from 436 transactions in 2021, according to its...more
On May 19, in response to Russia’s ongoing invasion of Ukraine, the United States, in coordination with allies and partners, announced new sanctions restrictions and export controls targeting Russia’s evasion networks,...more
6/5/2023
/ Asset Freeze ,
Avoidance ,
Banking Sector ,
Biden Administration ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Energy Sector ,
EU ,
Executive Orders ,
Export Controls ,
General Licenses ,
Military Conflict ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
UK ,
Ukraine
The year since Russia’s invasion of Ukraine has been marked by the development of a multi-jurisdictional, multi-agency sanctions regime in the United States, the United Kingdom and the European Union. Although coordination...more
4/28/2023
/ Asset Freeze ,
Asset Recovery ,
Compliance ,
Economic Sanctions ,
Enforcement ,
Enforcement Authority ,
EU ,
G7 ,
Member State ,
Military Conflict ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Regulatory Oversight ,
Russia ,
UK ,
Ukraine
Following a series of public reports, the United States appears close to announcing a new regulatory process to scrutinize US “outbound” investment to countries presenting national security challenges. ...more
2/22/2023
/ Acquisitions ,
CFIUS ,
Compliance ,
Covered Transactions ,
Cross-Border Transactions ,
Foreign Investment ,
Mergers ,
NAICS ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Outbound Transactions ,
Popular ,
Regulatory Agenda ,
Regulatory Requirements
Effective February 5, 2023, the Price Cap Coalition (the Coalition), consisting of the G7 nations, the European Union (EU) and Australia, set a price cap of $45 per barrel for “Discount to Crude” petroleum products of Russian...more
2/10/2023
/ Australia ,
Biden Administration ,
Crude Oil ,
Economic Sanctions ,
EU ,
Exports ,
G7 ,
General Licenses ,
New Guidance ,
Oil & Gas ,
Oil Prices ,
Russia ,
Ukraine
A ban on services related to the maritime transport of Russian-origin crude oil sold above a pre-determined price cap of $60 per barrel began on December 5, 2022, with a similar price cap ban related to other Russian-origin...more
12/7/2022
/ Australia ,
Commodities ,
Economic Sanctions ,
EU ,
Exports ,
G7 ,
Global Market ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Oil Prices ,
Russia ,
Ukraine
We wanted to share an update on Russia sanctions developments in the United States, United Kingdom, and European Union that occurred between March 24 and April 8, 2022. Following new reports of atrocities committed by the...more
We wanted to share an update on Russia sanctions developments in the United Kingdom, European Union, and the United States that occurred between March 16 and 24. As summarized below, key global jurisdictions have continued to...more
Western sanctions against Russia have continued to broaden substantially into new areas of trade, especially in the energy sector. Policymakers in Washington DC, Brussels, London and other allied capitals also continue to...more
3/18/2022
/ Asset Freeze ,
Belarus ,
Blocked Entities ,
Blocked Person ,
Cryptocurrency ,
Economic Sanctions ,
EU ,
Export Controls ,
General Licenses ,
Imports ,
Most-Favored Nations ,
Russia ,
Trade Relations ,
Trade Restrictions ,
UK ,
Ukraine
The United States, the European Union (EU), the United Kingdom (UK), and other allies and partners are implementing wide-ranging, novel sanctions and sweeping export controls against Russia in response to its invasion of...more
2/28/2022
/ Biden Administration ,
Blocked Entities ,
Blocked Person ,
Economic Sanctions ,
Embargo ,
EU ,
Financial Institutions ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
UK ,
Ukraine
Yesterday, the US Department of Homeland Security, on behalf of the interagency Forced Labor Enforcement Task Force (Task Force), published a Notice in the Federal Register that seeks public comment on the implementation of...more
End-of-Year Sanctions Target Chinese Supply Chains and AI, Quantum Computing, and Biotechnology -
Several US executive branch agencies and the US Congress have adopted wide-ranging end-of-year sanctions, export control and...more
12/29/2021
/ Artificial Intelligence ,
Biden Administration ,
Biotechnology ,
Bureau of Industry and Security (BIS) ,
China ,
Economic Sanctions ,
Entity List ,
Executive Orders ,
Export Controls ,
Foreign Issuers ,
Human Rights ,
International Relations ,
Military End Use ,
National Security ,
NDAA ,
New Legislation ,
Office of Foreign Assets Control (OFAC) ,
PCAOB ,
Popular ,
Publicly-Traded Companies ,
Supply Chain ,
Technology Sector ,
U.S. Commerce Department
On September 21, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) levied its first sanctions against a Russian-operated virtual currency exchange involved in ransomware payments and published an...more
9/24/2021
/ Advisory Opinions ,
AML/CFT ,
Anti-Money Laundering ,
Compliance ,
Cryptocurrency ,
Currency Exchange ,
Cybersecurity Information Sharing Act (CISA) ,
Economic Sanctions ,
FinCEN ,
Know Your Customers ,
Office of Foreign Assets Control (OFAC) ,
Ransomware ,
Russia ,
SDN List ,
U.S. Treasury ,
Virtual Currency