News & Analysis as of

Exports Office of Foreign Assets Control (OFAC) Due Diligence

BakerHostetler

Key Export Control Developments During the First Quarter of 2024

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The first quarter of 2024 saw numerous developments on the export control front. This report summarizes the key developments and provides links to the relevant Federal Register notices and/or agency announcements....more

Holland & Knight LLP

International Trade Compliance Year in Review: 10 Enforcement Lessons from 2022

Holland & Knight LLP on

In the past year, 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 State's Directorate of...more

Holland & Knight LLP

A Guide for Early-Stage Companies on Trade Compliance and Foreign Investment

Holland & Knight LLP on

Are you looking to hire a star engineer who is a foreign national? Are you considering raising capital from a foreign venture capital firm or other foreign investor? Are you interested in sourcing components or creating...more

American Conference Institute (ACI)

[Virtual Conference] Navigating Russia Sanctions Complexities - September 27th, 10:00 am - 5:00 pm EDT

Unravel the multiple layers of primary and secondary Russia Sanctions and strengthen your analytical decision-making process. The Russia sanctions landscape continues to evolve in many significant ways. ACI’s 4th...more

WilmerHale

OFAC Enforcement Actions Highlight Risks to Software Providers & MSBs

WilmerHale on

On April 29, 2021, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced two settlements of potential civil liability with two companies over their apparent violations of its regulations. The...more

Kelley Drye & Warren LLP

Recent OFAC Settlement Highlights Due Diligence Expectations When Selling to Intermediaries

Last week, the Office of Foreign Assets Control (OFAC) announced a settlement agreement with UniControl, Inc. (UniControl or “the company”) for shipping goods to European trading partners when UniControl knew or should have...more

Morrison & Foerster LLP

Following U.S. Lead, UK Office Of Financial Sanctions Implementation Issues Maritime Guidance

Much of the world’s focus is on the COVID-19 pandemic, and rightfully so, but sanctions regulators also have their gazes fixed on another issue: the maritime industry. On May 14 2020, we saw the U.S. Departments of State and...more

Womble Bond Dickinson

Key Developments in US Sanctions

Womble Bond Dickinson on

Global supply chains have been greatly disrupted by the COVID-19 pandemic, sending companies scrambling to find both new sources of supplies and new customers for their products. But even as businesses struggle to find their...more

Bass, Berry & Sims PLC

OFAC Settles with Cosmetics Company, Reiterates Importance of Supply Chain Compliance

• Company committed multiple apparent violations of U.S. sanctions on North Korea • Penalty imposed in part because of company’s “non-existent” sanctions compliance program • Settlement underscores need to address supply...more

King & Spalding

e.l.f. Cosmetics Agrees to Pay Nearly $1 Million To Settle Apparent Violations Of U.S. Sanctions Against North Korea

King & Spalding on

This Enforcement Action Underscores The Risks Of Sourcing Products Without Comprehensive Supply Chain Due Diligence - On January 31, 2019, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of the Treasury...more

Bass, Berry & Sims PLC

U.S. Dental Supply Company Penalized for Violating Iran Sanctions

Bass, Berry & Sims PLC on

•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

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - October 2017

ANTICORRUPTION DEVELOPMENTS – Global Compliance Overhaul for SAP as DOJ and SEC Investigate Payments Allegedly Related to South African Government Contracts – On October 26, 2017, German software company SAP SE...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - August 2017

ANTICORRUPTION DEVELOPMENTS - MTS Receives DOJ and SEC Declination Letters Concluding FCPA Investigations - On August 7, 2017, MTS Systems (MTS), a Minnesota based maker of test systems and industrial position...more

Perkins Coie

Court Opinion on Liability for Re-Exports to Iran Spurs Practical Guidance for U.S. Exporters

Perkins Coie on

A recent federal appeals court decision addresses a familiar issue for many companies: When can a U.S. exporter be liable for a product that is re-exported to a sanctioned country, such as Iran? This update summarizes the...more

Kelley Drye & Warren LLP

Epsilon Case Highlights the Need for Sanctions Due Diligence on Resellers

As global companies begin to reenter the Iranian market, a decision issued by the U.S. District Court for the District of Columbia is an important reminder that resellers and distributors can generate liability for U.S....more

Baker Donelson

Iran – Don’t Forget the General License!

Baker Donelson on

Iran entered into a historic nuclear agreement with the U.S. and other world powers on July 14th 2015. The agreement will allow the licensing of the export, re-export, sale, lease or transfer to Iran of commercial passenger...more

Williams Mullen

Export Control Laws for the General Counsel

Williams Mullen on

You are the chief legal officer of a U.S. company. Your CEO walks into your office and announces that your company is about to conclude its first international sale. In addition, the company has just appointed distributors in...more

Dorsey & Whitney LLP

Practical Guidance for Dealing with OFAC’s Recently Released Ukraine Related Sanctions Regulations and the EU’s Ukraine Sanctions

Dorsey & Whitney LLP on

On May 8, 2014, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued regulations to implement three Executive Orders issued by President Obama in March regarding the situation in Ukraine. The...more

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