The New Cold War: Risk, Sanctions, Compliance Episode 22: "Focus on Iran: Protests, Sanctions and Oil"
EMBARGOED! Episode 43: Russia and Iran and China, Oh My!
Washington Post Journalist Jason Rezaian on His Iranian Imprisonment
Nota Bene Episode 64: U.S. Check In: Prescription Drugs, USMCA, Privacy, Impeachment and Iran with Elizabeth Frazee and Jonathan Meyer
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
In 2023, the European Union continued to use economic sanctions as one of its foreign policy tools, and not only in response to Russia’s war in Ukraine. New sanctions and adjustments to existing regimes reflect the EU’s...more
In 2023, the biggest question on clients’ minds was the ramping up of U.S. export controls targeting semiconductors and advanced computing. In October, the U.S. Commerce Department unveiled new rules to tighten further a...more
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
The pessimist complains about the wind; the optimist expects it to change; the realist adjusts the sails. – William Arthur Ward The U.S. maritime industry is much like a great ship: It is subject to unforeseen forces, and it...more
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
July saw two noteworthy Russia enforcement actions. A Russian national was arrested in Estonia and extradited to the United States after being charged with conspiring to procure U.S.-origin technologies and ammunition on...more
The U.S. Department of Justice (DOJ), Department of Commerce's Bureau of Industry and Security (BIS) and Department of the Treasury's Office of Foreign Assets Control (OFAC) on July 26, 2023, issued a Tri-Seal Compliance Note...more
On June 16, the U.S. Department of Commerce published a final rule, to be effective July 17, implementing the Protecting Americans’ Sensitive Data From Foreign Adversaries and amending the Securing the Information and...more
You are reading the April 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. -We saw...more
The U.S. Department of Justice (“DOJ”) on May 16 announced criminal charges and arrests that highlight risks for companies from U.S. and non-U.S. networks and individuals that seek to unlawfully divert U.S. goods, services,...more
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
Russia - Russian National Charged with Supplying U.S. Technology to the Russian and North Korean Governments (DOJ Action) Those involved. Ilya Balakaev, Russian national. Charges and penalties. Conspiracy to...more
2022 was an unprecedented year for U.S. sanctions and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). While the sweeping new U.S. sanctions imposed against Russia and Belarus in unparalleled...more
After months of negotiations, Congress revealed the compromise version of the National Defense Authorization Act for Fiscal Year 2023 (NDAA) on December 6, 2022. The bill, viewed as a “must-pass” piece of legislation because...more
The world’s response to Russia’s invasion of Ukraine dominated the first quarter of 2022, as the US and its international partners coordinated efforts to impose unprecedented sanctions designed to isolate the Russian...more
Last week, the House Permanent Select Committee on Intelligence (HPSCI) and the Senate Select Committee on Intelligence (SSCI) each held a hearing on the US Intelligence Community’s (IC) 2022 Annual Threat Assessment, a...more
2021 was a year of transition in the United States and for the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). OFAC’s year, while busy, was far different from 2020, as the Biden Administration’s...more
The U.S. Government is continuing its frequent and highly visible use of denied party lists as an important tool in administering the export control laws. Each of the Bureau of Industry and Security (BIS), the Office of...more
The US Treasury Department has released its 2021 Sanctions Review (the “Review”), which describes the US sanctions framework and the agency’s future sanctions priorities. The Review reflects on the evolution over two decades...more
The Justice Department recently announced a settlement with Avnet Asia for illegal shipments of sensitive U.S. commodities to China and Iran. Under the settlement, DOJ agreed to a non-prosecution agreement (NPA) in exchange...more
Despite a shift in the sanction landscape, it will take time for enforcement activity to catch up. As a result, organizations should regularly examine their exposure with business partners around the globe and consult with...more
Turning to the business of exports from the United States, the next section is a must-read for any company doing business in the United States or from the United States. Or for that matter, any company competing with affected...more
Doubling down on an America First foreign policy, a second term for President Trump would focus on continued unwinding post 9/11 military involvement in the Middle East while pursuing normalization of ties between Israel and...more
Report on Supply Chain Compliance 3, no. 7 (April 2020) The United States Department of the Treasury’s Office of Foreign Assets Control has stayed busy during the coronavirus outbreak. The office made several new additions...more