Key Points - On May 21, 2024, the DOJ announced its first ever declination under the NSD’s updated Enforcement Policy, declining to prosecute Sigma-Aldrich Inc., d/b/a MilliporeSigma (a subsidiary of Merck KGaA, Darmstadt,...more
6/7/2024
/ Bureau of Industry and Security (BIS) ,
Corporate Counsel ,
Department of Justice (DOJ) ,
Directorate of Defense Trade Controls (DDTC) ,
Enforcement ,
Export Controls ,
Incentives ,
National Security ,
Non-Prosecution Agreements ,
Office of Foreign Assets Control (OFAC) ,
Sanction Violations ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
White Collar Crimes
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
While media reporting has predominantly focused on the provisions in the emergency foreign aid package that President Biden signed into law on April 24, 2024 that provides funding for Ukraine, Israel and Taiwan, House Foreign...more
5/1/2024
/ Department of Justice (DOJ) ,
Drug Trafficking ,
Economic Sanctions ,
International Emergency Economic Powers Act (IEEPA) ,
National Security ,
New Legislation ,
Office of Foreign Assets Control (OFAC) ,
Reporting Requirements ,
Sanction Violations ,
Statute of Limitations ,
TWEA
Key Points -
On December 22, 2023, President Biden issued E.O. 14114 “Taking Additional Steps With Respect to the Russian Federation’s Harmful Activities.” Specifically, E.O. 14114, which amends E.O. 14024 and E.O. 14068,...more
1/19/2024
/ CAPTA List ,
Certification Requirements ,
Criminal Prosecution ,
Customs and Border Protection ,
Due Diligence ,
Economic Sanctions ,
Executive Orders ,
FinCEN ,
Foreign Financial Institutions (FFI) ,
Forfeiture ,
Imports ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Prohibited Transactions ,
Russia ,
SDN List ,
Supply Chain
Within the trade bar there is cautiousness, curiosity and skepticism at the numerous pronouncements signaling greater enforcement of export controls and sanctions by the Bureau of Industry and Security, the Office of Foreign...more
12/14/2023
/ Anti-Money Laundering ,
Bureau of Industry and Security (BIS) ,
China ,
Civil Monetary Penalty ,
Criminal Investigations ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement ,
Export Administration Regulations (EAR) ,
Export Controls ,
FinCEN ,
Foreign Corrupt Practices Act (FCPA) ,
Investigations ,
Iran ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanction Violations ,
U.S. Commerce Department ,
Whistleblowers
On July 26, 2023, the departments of Commerce, Justice and the Treasury issued their second ever to date “Tri-Seal Compliance Note” (the “Note”). It describes expectations for the voluntary disclosure of sanctions, export,...more
8/7/2023
/ Anti-Corruption ,
Bureau of Industry and Security (BIS) ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Export Controls ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Sanction Violations ,
U.S. Commerce Department ,
U.S. Treasury ,
Voluntary Disclosure