On April 12, 2024, in coordination with the United Kingdom, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued two new Determinations (collectively, the “Determinations”) that together prohibit...more
This is the tenth in our 2024 Year in Preview series examining important trends in white collar law and investigations in the coming year. Our previous post, "Health Care Fraud Enforcement in 2024," can be found here....more
4/18/2024
/ Bureau of Industry and Security (BIS) ,
Compliance ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
International Trade ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
US Trade Policies ,
White Collar Crimes
On February 23, 2024, the Biden administration announced more than 500 sanctions on individuals and entities inside the Russian Federation and entities outside of Russia determined to be supporting Russia’s war effort....more
On December 22, 2023, President Biden issued a new Executive Order affecting foreign financial institutions and those importing certain goods into the U.S.
In addition, OFAC provided related new and revised FAQs, as well...more
U.S. authorities have been active in November 2023, reinforcing and expanding sanctions targeting Russia's war effort in Ukraine. Multiple agencies added sanctions targeting entities involved in Russia's military supply...more
On July 20, 2023, the Department of Treasury’s Office of Foreign Asset Control (“OFAC”) designated additional entities in order to further disrupt Russian access to military supplies and deprive the Russian government of...more
On July 16, 2023, Russian President Vladimir Putin signed a decree seizing control of the Russian subsidiaries of the French food-products company, Danone S.A., and Danish brewer, Carlsberg A/S, claiming the assets were being...more
On May 19, 2023, the United States along with other members of the G7 and other allied countries imposed additional sanctions and export controls meant to further restrict Russian economic activity and degrade Russia’s...more
6/5/2023
/ Aircraft ,
Belarus ,
Economic Sanctions ,
Entity List ,
Export Controls ,
Exports ,
Financial Services Industry ,
Office of Foreign Assets Control (OFAC) ,
Research and Development ,
Russia ,
Technology Sector ,
Transportation Industry ,
U.S. Commerce Department ,
Ukraine ,
US Department of State ,
Vessels
The centrality of international trade laws in the development and execution of U.S. foreign policy has never been more evident than in 2022. Companies that have not invested in international trade compliance programs are...more
4/21/2023
/ Belarus ,
Biden Administration ,
Bureau of Industry and Security (BIS) ,
CFIUS ,
China ,
Economic Sanctions ,
Enforcement Actions ,
EU ,
Export Controls ,
Financial Services Industry ,
Foreign Direct Investment ,
Human Rights ,
International Trade ,
Iran ,
National Security ,
Nicaragua ,
Russia ,
Trade Restrictions ,
U.S. Commerce Department ,
UK ,
US Department of State ,
Uyghur Forced Labor Prevention Act (UFLPA) ,
Venezuela ,
Virtual Currency ,
Withhold Release Orders (WROs)
In order to continue restricting Russia’s ability to finance war efforts against Ukraine, on February 3, 2023, the G7 nations implemented two new price caps on seaborne petroleum products that originate in Russia (“Russian...more
Following the initial announcement in September 2022 by the Group of Seven Nations (“G7”) that they would set a price cap on Russian-origin oil and petroleum products, the U.S., the EU, and the UK have moved to implement the...more
U.S. augments current sanctions on Nicaragua by imposing additional sanctions on the Nicaraguan mining authority and the former Nicaraguan head of state security, and expanding sanctions authorities allowing the U.S. to...more
I. OFAC Prohibits Gold Importation from the Russian Federation -
Implementing the declaration of G-7 leaders on June 26, 2022, the United States has joined the UK, Canada and Japan in prohibiting the importation of newly...more
I. OFAC Publishes FAQs Addressing Ban on New Investment in Russia On April 6, 2022, President Biden signed Executive Order (“EO”) 14071, which prohibits all “new investment in the Russian Federation by a United States...more
BIS Imposes New Export Controls on Certain Industrial EAR99 Items -
Currently, all items on the Export Administration Regulations’ (“EAR“) Commerce Control List (“CCL”) require a license for export, re-export or transfer...more
6/14/2022
/ Belarus ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Entity List ,
EU ,
Export Controls ,
General Licenses ,
Imports ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
UK ,
Ukraine
I. U.S. Persons Prohibited from Providing Accounting, Trust and Corporate Formation, and Management Consulting Services to Russia -
On May 8, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control...more
U.S. Actions Following increased sanctions on Russian banks and a new Executive Order banning investment in the Russian Federation (reported by Foley Hoag here), on April 7, 2022, the U.S. sanctioned two major Russian...more
I. New Executive Order Bans U.S. Investment in Russia -
On April 6, 2022, President Biden issued a new Executive Order, “Prohibiting New Investment in and Certain Services to the Russian Federation in Response to...more
4/8/2022
/ Asset Freeze ,
Banking Sector ,
Biden Administration ,
Cyber Crimes ,
Economic Sanctions ,
Executive Orders ,
Financial Institutions ,
Investment ,
Investors ,
Office of Foreign Assets Control (OFAC) ,
Ransomware ,
Russia
U.S. Sanctions -
The U.S. continued to expand its Russia-related sanctions with new additions to the Specially Designated Nationals and Blocked Persons List (“SDN List”) made by the U.S. Department of the Treasury’s Office...more
On March 11, 2022, President Biden signed a new Russia-related Executive Order, Prohibiting Certain Imports, Exports, and New Investment with Respect to Continued Russian Federation Aggression (“March 11 E.O.”)....more
3/16/2022
/ Belarus ,
Biden Administration ,
Cryptocurrency ,
Economic Sanctions ,
Entity List ,
Executive Orders ,
Financial Institutions ,
Financial Transactions ,
Investment ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Vladimir Putin
I. Biden Administration Import and Investment Ban Related to Russian Energy -
On March 8, 2022, the Biden administration announced its widely anticipated ban on the import of Russian oil and other energy-related...more
3/14/2022
/ Belarus ,
Biden Administration ,
Economic Sanctions ,
Energy Sector ,
EU ,
Export Controls ,
Financial Institutions ,
FinCEN ,
General Licenses ,
Imports ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Russia ,
UK ,
Ukraine
Key Takeaways:
• U.S. imposes additional sanctions on Russian elites, along with their family members, companies, and personal vehicles
• Actions targeting the defense sector and Russian government-affiliated media...more
3/8/2022
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Executive Orders ,
Export Controls ,
Financial Transactions ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
SWIFT ,
Ukraine
On February 28, 2022, the U.S. government announced new sanctions on the Central Bank of Russia, National Wealth Fund, Ministry of Finance, and Russian Direct Investment Fund, dramatically increasing the economic impact of...more
3/2/2022
/ Biden Administration ,
Economic Sanctions ,
Enforcement Priorities ,
Executive Orders ,
Export Controls ,
Financial Transactions ,
Foreign Currency ,
Foreign Trade Regulations ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Ukraine
As we had reported in our earlier client alert and 2022 Year in Preview, Russia’s invasion of Ukraine has resulted in a new wave of sanctions and export controls on Russia, including sanctions on key sectors of the Russian...more
2/28/2022
/ Australia ,
Canada ,
China ,
Economic Sanctions ,
EU ,
Export Controls ,
Exports ,
Financial Institutions ,
Financial Services Industry ,
Japan ,
Licensing Rules ,
New Zealand ,
Russia ,
SDN List ,
Sovereign Debt ,
UK ,
Ukraine ,
Vladimir Putin
This is the fifth post in this year’s series examining important trends in white collar law and investigations. Our previous post discussed trends in State AG enforcement. Up next: SEC Enforcement in 2022: A Look Ahead. ...more
2/25/2022
/ Afghanistan ,
Belarus ,
Biden Administration ,
Bureau of Industry and Security (BIS) ,
Burma ,
Cambodia ,
CFIUS ,
China ,
Cuba ,
Economic Sanctions ,
Enforcement ,
Ethiopia ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Human Rights ,
International Criminal Court ,
Iran Sanctions ,
ITAR ,
Joint Comprehensive Plan of Action (JCPOA) ,
Myanmar ,
Nicaragua ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
SDN List ,
Securities and Exchange Commission (SEC) ,
Sudan ,
U.S. Treasury ,
Uyghur Forced Labor Prevention Act (UFLPA) ,
Venezuela ,
Virtual Currency ,
Withhold Release Orders (WROs)