Russia -
Former Special Agent in Charge of the FBI New York Counterintelligence Division Charged with Violating U.S. Sanctions on Russia (DOJ)
Those involved. Charles McGonigal, former Special Agent in Charge of the FBI...more
2/8/2023
/ Banking Sector ,
Bureau of Industry and Security (BIS) ,
California ,
China ,
Conspiracies ,
Criminal Convictions ,
Criminal Prosecution ,
Department of Labor (DOL) ,
Enforcement Actions ,
Espionage ,
Export Control Reform Act (ECRA) ,
Export Controls ,
Exports ,
FBI ,
FCPA Corporate Enforcement Policy (CEP) ,
Financial Institutions ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
International Emergency Economic Powers Act (IEEPA) ,
Iran ,
Iran Sanctions ,
Money Laundering ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Russia ,
Self-Disclosure Requirements ,
Venezuela
Russia -
Active Russian Agent Indicted for Scheme to Violate Sanctions in the United States (DOJ Action)
Those involved. Andrii Derkach, a Ukrainian national and – according to the DOJ – an “Active Russian Agent.”...more
1/13/2023
/ China ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Exports ,
Federal Contractors ,
Foreign Corrupt Practices Act (FCPA) ,
ITAR ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Securities and Exchange Commission (SEC) ,
Settlement
The Bass, Berry & Sims international trade team continues to monitor U.S. government action in response to Russia’s invasion of Ukraine. In the final months of 2022, the U.S. government added multiple individuals and entities...more
You are reading Bass, Berry, & Sims’ new enforcement roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox every month.
...more
12/9/2022
/ Bureau of Industry and Security (BIS) ,
China ,
Criminal Prosecution ,
Cryptocurrency ,
Department of Justice (DOJ) ,
DFARS ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Illegal Imports ,
International Trade ,
Iran ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Trade Secrets
The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and...more
The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and...more
7/8/2022
/ Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Financial Transactions ,
FinCEN ,
General Licenses ,
Gold ,
Imports ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Trade Restrictions ,
Ukraine
The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and...more
6/7/2022
/ Belarus ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Enforcement ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Final Rules ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Transparency ,
Ukraine
The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and...more
The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and...more
5/6/2022
/ Aircraft ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Prohibited Transactions ,
Russia ,
U.S. Commerce Department ,
Ukraine
The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and...more
...President Biden Extends National Emergency under Executive Order 14024 -
On April 13, President Biden extended the national emergency declared under Executive Order (EO) 14024 for an additional year due to the harmful...more
4/19/2022
/ Belarus ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Financial Institutions ,
Joe Biden ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
U.S. Commerce Department ,
Ukraine
The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and...more
4/12/2022
/ Belarus Sanctions ,
Biden Administration ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Direct Product Rule ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Ukraine
The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and...more
4/6/2022
/ Belarus Sanctions ,
Biden Administration ,
Economic Sanctions ,
Executive Orders ,
Export Controls ,
Foreign Trade Regulations ,
General Licenses ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Ukraine
The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes the evolving situation as of...more
The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes the evolving situation as of...more
The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes the evolving situation as of...more
3/15/2022
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Financial Institutions ,
Foreign Investment ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Ukraine
This UPDATED post summarizes the situation as of late evening on Monday, March 7, concerning current U.S. sanctions and export restrictions related to Russia and Ukraine...more
3/8/2022
/ Belarus ,
Economic Sanctions ,
Export Controls ,
Foreign Direct Investment ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
South Korea ,
U.S. Commerce Department ,
Ukraine
This UPDATED post summarizes the situation as of late evening on Thursday, March 3, concerning current U.S. sanctions and export restrictions related to Russia and Ukraine...more
3/4/2022
/ Asset Freeze ,
Belarus Sanctions ,
Departments of Commerce ,
Economic Sanctions ,
Entity List ,
Export Controls ,
Final Rules ,
Foreign Direct Investment ,
Foreign Relations ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Ukraine
This UPDATED post summarizes the situation as of late evening on Monday, February 28, concerning current U.S. sanctions and export restrictions related to Russia and Ukraine. This post supplements our post of late evening on...more
3/1/2022
/ Asset Freeze ,
Banks ,
Biden Administration ,
Economic Sanctions ,
Executive Orders ,
Export Controls ,
Exports ,
Financial Institutions ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SWIFT ,
Ukraine
This UPDATED post summarizes the situation as of late evening on Friday, February 25, concerning current U.S. sanctions and export restrictions related to Russia and Ukraine. This post supplements our post of late evening on...more
2/28/2022
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Controls ,
Exports ,
Licensing Rules ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
U.S. Commerce Department ,
Ukraine ,
Vladimir Putin
This UPDATED post summarizes the situation as of late evening on Thursday, February 24, concerning current U.S. sanctions and export restrictions related to Russia and Ukraine. This supplements our post of late evening on...more
• Virtually all transactions with government prohibited
• Most transactions with private sector parties still permitted
• Practical challenges make Venezuela transactions difficult, including for non-U.S. parties
On...more
• Previously permissible activities must be wound down in 90 or 180 days
• Non-U.S. companies at particular risk of enforcement action
• Only limited guidance issued so far, unclear what authority U.S. companies...more
•Many medical products can be exported to Iran – so long as a license is obtained
•Imposition of successor liability underscores importance of pre-transaction due diligence
•OFAC enforcement, as in the past, continues...more
1/10/2018
/ Aggravating Factors ,
Distributors ,
Due Diligence ,
Enforcement Actions ,
Exports ,
Iran Sanctions ,
Licenses ,
Manufacturers ,
Medical Supplies ,
Mergers ,
Mitigating Factors ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Sanction Violations ,
Statute of Limitations ,
Subsidiaries ,
Successor Liability ,
Voluntary Disclosure
It is rare for companies to go to court to fight penalties imposed by the Office of Foreign Assets Control (OFAC) for violations of U.S. sanctions. It is even more rare for a court to make any sort of finding against the...more
6/24/2017
/ Administrative Procedure Act ,
Appeals ,
Arbitrary and Capricious ,
Economic Sanctions ,
Enforcement Actions ,
Exports ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Remand ,
Sanction Violations ,
Subpoenas