The U.S. agencies most well-known for their enforcement of U.S. trade and national security laws are the Bureau of Industry and Security (“BIS”), the Directorate of Defense Trade Controls (“DDTC”), the Office of Foreign...more
In a move that highlights the U.S. government’s ongoing fight against evasion of sanctions and export control laws, the Departments of the Treasury, Commerce, and Justice yesterday published yet another Tri-Seal Compliance...more
Receiving an administrative subpoena, summons, or other request for information from a federal U.S. agency can be surprising, but it is not an uncommon scenario in the trade world. The main agencies in charge of administering...more
The United States Office of Foreign Assets Control (“OFAC”) issued an Alert on April 17, 2023, warning U.S. persons about the possible evasion of the price cap imposed by the Department of Treasury on Russian oil. Pursuant to...more
This week’s episode covers the “new trend” of suing and challenging OFAC decisions and discusses some recent lawsuits against OFAC. Host Olga Torres is joined by Erich Ferrari, Founder and Principal Attorney of Ferrari &...more
On February 24, 2023, the one-year anniversary of Russia’s invasion of Ukraine, the White House announced a series of actions that the U.S. and Group of 7 (“G7”) will take to support Ukraine and impose further costs on...more
2/27/2023
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Controls ,
G7 ,
Humanitarian Assistance ,
Military Conflict ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Tariffs ,
Ukraine ,
World Bank
On May 23, 2022, President Joe Biden, when asked whether the United States would get involved militarily if China invaded Taiwan, answered firmly, “Yes. That’s the commitment we made.” As the world watches the war in Ukraine,...more
6/1/2022
/ Biden Administration ,
China ,
Economic Sanctions ,
Export Controls ,
Foreign Policy ,
Foreign Relations ,
Imports ,
Military Conflict ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Taiwan ,
Uyghur Forced Labor Prevention Act (UFLPA)
As the U.S. and the European Union continue to impose new sanctions on Russia in response to the invasion of Ukraine, regulatory authorities continue their pursuit of companies and individuals who violate those sanctions. The...more
4/28/2022
/ Acquisitions ,
Corruption ,
Economic Sanctions ,
Enforcement Actions ,
Financial Transactions ,
Foreign Policy ,
Military Conflict ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanction Violations ,
Ukraine
Civil and criminal penalties levied against U.S. companies for trade violations are just the beginning of the potential unforeseen costs of doing business in the global marketplace. What cannot be quantified are the countless...more
1/26/2022
/ Bureau of Industry and Security (BIS) ,
Corruption ,
Department of Justice (DOJ) ,
Directorate of Defense Trade Controls (DDTC) ,
Economic Sanctions ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Exports ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Policy ,
Foreign Relations ,
Imports ,
ITAR ,
Office of Foreign Assets Control (OFAC) ,
Sanction Violations ,
Securities and Exchange Commission (SEC) ,
Trade Relations ,
US Trade Policies ,
White Collar Crimes
View PDF Version of Article In recent years, the U.S. Government (“USG”) has taken numerous actions to target forced labor and other human rights violations, with a significant increase in 2020 and early 2021. These include...more
10/27/2021
/ Bureau of Industry and Security (BIS) ,
Corporate Social Responsibility ,
Customs and Border Protection ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Federal Acquisition Regulations (FAR) ,
Forced Labor ,
Human Rights ,
Human Trafficking ,
Imports ,
Office of Foreign Assets Control (OFAC) ,
Supply Chain ,
Withhold Release Orders (WROs)
On September 21, 2021, in a first-of-it-kind action, the U.S. Department of the Treasury Office of Foreign Assets Control (“OFAC”) imposed economic sanctions on SUEX OTC, S.R.O. (“SUEX”), a virtual currency exchange, for...more
10/27/2021
/ Blocked Person ,
Crypto Exchanges ,
Cyber Attacks ,
Economic Sanctions ,
Enforcement Actions ,
Financial Transactions ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Ransomware ,
Regulatory Violations ,
SDN List