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Adams and Reese LLP

International Compliance Digest – August 2024

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August was another robust month in international trade that further signifies the need for corporations to invest in effective compliance programs. For starters, the DOJ unveiled a new program that incentivizes corporate...more

Morgan Lewis

Commerce Issues First-Ever Ban on Information and Communications Technology and Services Transactions Under EO 13873

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The Department of Commerce’s Bureau of Industry and Security (BIS) published a 13-page Final Determination on June 24, 2024 concerning cybersecurity and antivirus software supplied by a US subsidiary of a Russia-based...more

The Volkov Law Group

Sanctions Compliance: Understanding the Red Lines of Enforcement (Part I of II)

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In this new era of aggressive sanctions enforcement, companies have to understand the red lines that define where criminal and civil enforcement risk increase.  In contrast to the history of FCPA enforcement, DOJ and OFAC...more

Adams and Reese LLP

International Compliance Digest – May 2024

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May saw the long-awaited release of the USTR’s Section 301 review. USTR confirmed that the Trump-era tariffs will remain in place, and raised those tariffs by another $18 billion on manufacturing, critical minerals, solar...more

Hogan Lovells

Statute of limitations extended for violations of U.S. sanctions

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Congress has doubled the statute of limitations for violations of most U.S. sanctions programs administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control.  Companies should be aware of the...more

Vinson & Elkins LLP

Not So Fast: Congress Doubles Statute of Limitations Period for U.S. Sanctions Violations in Foreign Aid Bill

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Following months of delays and intense debate in Congress, President Biden signed H.R. 815 into law on April 24, 2024, which made headlines for funding $95 billion in military aid to Ukraine, Israel, and Taiwan, along with...more

The Volkov Law Group

DOJ Charges Ten Individuals for Violating Venezuelan Sanctions

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On April 22, 2024, the U.S. Department of Justice announced the indictment of 10 Venezuelan individuals for conspiring to violate the International Economic Emergency Powers Act (“IEEPA”). According to the DOJ, the...more

Womble Bond Dickinson

DOJ Enhancing Its Sanctions Toolkit

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President Biden recently signed a foreign aid bill that will have significant implications for United States sanctions enforcement, specifically Section 206 of the International Emergency Economic Powers Act (50 U.S.C. 1705)...more

Foley Hoag LLP - White Collar Law &...

Enforcement of U.S. Trade Sanctions and Export Controls in 2023 and What to Expect In 2024

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

The Volkov Law Group

DOJ, Commerce and Treasury Issue JCN on Foreign Person Liability for Sanctions and Export Controls Violations

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As DOJ, OFAC and BIS ramp up sanctions and export controls enforcement, they have continued to provide important compliance guidance.  You have to give the enforcement agencies credit — on the one hand, they regularly warn of...more

Adams and Reese LLP

International Compliance Digest – March 2024

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International Compliance Digest is the new Adams and Reese monthly newsletter focused on international trade compliance and enforcement. Each month we will bring you the latest in compliance and enforcement updates, including...more

Locke Lord LLP

OFAC, BIS and DOJ Issue TriSeal Guidance on Obligations of Non-U.S. Persons to Comply With U.S. Sanctions and Export Control Laws

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On March 5, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) and the U.S. Department of Justice (“DOJ”) issued a...more

WilmerHale

U.S. Agencies Caution Foreign-Based Persons on Extraterritorial Reach of U.S. Sanctions and Export Control Regulations

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On March 6, 2024, the U.S. Departments of the Treasury, Commerce, and Justice jointly issued a Tri-Seal Compliance Note titled “Obligations of Foreign-Based Persons to Comply with U.S. Sanctions and Export Control Laws”...more

Holland & Knight LLP

New Tri-Seal Compliance Note Issued to Non-U.S. Persons

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The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC), U.S. Department of Commerce's Bureau of Industry and Security (BIS) and U.S. Department of Justice (DOJ) on March 6, 2024, issued a Tri-Seal...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – February 2024 Update

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February saw a continuing focus on Russia. First, the Treasury Department’s Office of Foreign Assets Control (OFAC), in conjunction with the State Department, sanctioned over 500 individuals and entities – the “largest number...more

Lowenstein Sandler LLP

Trade Matters - Lowenstein Sandler's Global Trade & National Security Newsletter - March 2024

On February 24, the two-year anniversary of Russia’s invasion of Ukraine, the Biden administration issued hundreds of new Russia-related export controls and sanctions. The Office of Foreign Assets Control (OFAC) and the...more

Morrison & Foerster LLP

U.S. Sanctions Enforcement: 2023 Trends and Lessons Learned

Today’s alert—the second in our Sanctions 2023 Year in Review Series—provides an overview of U.S. sanctions enforcement in 2023, including the key lessons learned from the public enforcement actions issued by the U.S....more

Venable LLP

Freight Forwarders and Common Carriers: As You Look Ahead to 2024, Do You "Know Your Cargo"?

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As federal regulators have recently made clear, steamship lines, non-vessel-operating common carriers, indirect air carriers, freight forwarders, and others involved in the global movement of cargo must ensure that their...more

Lowenstein Sandler LLP

Trade Matters - Lowenstein Sandler's Global Trade & National Security Newsletter - January 2024

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On December 11, the Department of Justice, the Department of Commerce’s Bureau of Industry and Security (BIS), the Department of Homeland Security, the Department of State’s Directorate of Defense Trade Controls (DDTC), and...more

K&L Gates LLP

US Government Highlights Sanctions and Export Control Obligations to Improve Compliance and Prevent Evasion

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Driven by concerns around increasing sanctions evasion activities by Russia, China, Iran and North Korea, the US Government is stepping up enforcement and warning companies in the extended cargo and shipping supply chain to...more

Seward & Kissel LLP

“Quint-Seal” Compliance Note Highlights Intensifying U.S. Government Enforcement of Sanctions and Export Control Laws in the...

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On December 12, 2023, the Department of Justice (DOJ), Department of Commerce’s Bureau of Industry and Security (BIS), Department of Homeland Security’s Homeland Security Investigations (HSI), the Department of State’s...more

Akin Gump Strauss Hauer & Feld LLP

7 Enforcement Predictions For US Export Controls, Sanctions

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

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – November 2023 Update

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You are reading the November 2023 Update of the Bass, Berry & Sims Enforcement Roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox. ...more

The Volkov Law Group

DOJ Repeats Warnings on Aggressive Criminal Enforcement of Sanctions and Export Controls

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As everyone knows, I tend to repeat myself — DOJ does as well.  Over the past year, DOJ has warned global companies — over and over — about the coming criminal enforcement storm against companies for sanctions and export...more

The Volkov Law Group

BIS and FinCEN Release Joint Notice Concerning Global Export Control Evasion

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On November 6, 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) and the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) released a new joint notice concerning...more

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