Everyone Come to Play: Exploring FOCI Mitigation Instruments
Podcast - FOCI Mitigation: SSAs, SCAs and Proxy Agreements
Leaders in Law: The State of International Trade with Neena Shenai
Understanding FOCI Mitigation
Podcast - Navigating M&A Due Diligence: Safeguarding Security Clearances
An In-Depth Overview of the DCSA
Ask a CFIUS Expert: Is Crypto Spying on Us?
Podcast - Change Condition Packages: Tips for Cleared Contractors
Podcast - Corporate Documents in the Context of Clearances
Decoding the Key Management Personnel Requirements
Navigating Personnel Security Clearances (PCLs)
Wiley's 10 Key Trade Developments: Outbound Investments and CFIUS Review
What Is an FCL and How Do I Obtain One?
AGG Talks: Cross-Border Business - How Foreign Companies Can Protect Their IP and Brand in the U.S.
Emerging Technology in the FY24 NDAA
John Neiman on the Corporate Transparency Act
Wiley's 10 Key Trade Developments: Evolution of Export Controls
FINCast Ep. 39 – State of Russia Sanctions Two Years After the Invasion
AGG Talks: Cross-Border Business - Privacy & Cybersecurity Considerations for Non-U.S. Companies
Video: Making Trade Inclusive for All Americans: A Conversation with SAP's Michelle Trong Perrin-Steinberg
You are reading the October 2024 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
On April 24, 2024, President Biden signed into law a long-debated $98 billion foreign aid and national security legislative package (the “Act”) providing funds for Israel, Taiwan, and Ukraine, and authorizing new sanctions...more
Congress continues to put pressure on the Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”), increasingly informing the context in which the Committee conducts its work. Last week, for...more
TRADE TIP OF THE MONTH: New Companies Have More Time To Report Ownership- The Treasury Department’s Financial Crimes Enforcement Network issued a final rule in late November to delay the deadline for newly created...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
On Wednesday, July 26, the Departments of Commerce, Treasury, and Justice issued a Tri Seal Compliance Note detailing the voluntary self-disclosure of potential violations for export controls, sanctions, and other national...more
The U.S. Department of Justice (DOJ), the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published their second Tri-Seal...more
On July 26, 2023, the departments of Commerce, Justice and the Treasury issued their second ever to date “Tri-Seal Compliance Note” (the “Note”). It describes expectations for the voluntary disclosure of sanctions, export,...more
On June 26, 2023, the Departments of Justice, Commerce, and Treasury issued a Tri-Seal Compliance Note that summarizes agency policy memoranda and existing regulations on voluntary self-disclosures (VSDs) of export controls...more
On July 26, 2023, the U.S. Departments of Justice, Treasury, and Commerce issued a joint compliance note (“JCN”) regarding voluntary self-disclosure (“VSD”) policies that apply to potential violations of U.S. sanctions...more
On July 26, the Department of Commerce, the Department of the Treasury, and the Department of Justice released a joint compliance notice (the “Compliance Notice”) updating and summarizing each agency’s position regarding the...more
On July 26, 2023, the U.S. Department of Justice’s (DOJ’s) National Security Division (NSD), the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), and the U.S. Department of the Treasury’s Office of Foreign...more
On July 26, the Department of Commerce, Department of the Treasury, and Department of Justice released a Tri-Seal Compliance Note (July Note) providing guidance on voluntary self-disclosure of potential violations of U.S....more
United States international trade regulatory agencies have updated voluntary self-disclosure (“VSD”) policies and guidance in an effort to incentivize private sector companies and individuals to self-report violations of U.S....more
On July 26, 2023, the Department of Justice (“DOJ”), the Department of Commerce’s Bureau of Industry and Security (“BIS”), and the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published their second...more
Executive Summary - The North Korean threat to the crypto ecosystem is the highest form of immediate risk to the crypto-economy driven by a regime that seeks to profit from its misuse to reinforce its regime and fuel all its...more
Editor’s Note: On July 27, 2022, HaystackID shared an educational webcast on the topic of Committee on Foreign Investment in the United States (CFIUS) compliance. CFIUS is a U.S. government interagency committee with the...more
In line with the Biden administration’s declaration last year that anticorruption is a “core United States national security interest,” sanctions evasion enforcement rapidly has become a core priority for the Department of...more
The interagency Committee on Foreign Investment in the United States (CFIUS or the Committee) hosted its 2022 Inaugural Conference on June 16, 2022. In its capacity as chair of CFIUS, the U.S. Department of the Treasury...more
In 2022, automotive suppliers face many of the same issues that have bedeviled the industry throughout 2021, as well as a host of all-new challenges. Unfortunately, as with many aspects of pre-pandemic life, the relative...more
On November 8, 2021, the U.S. Department of Justice (“DOJ”), U.S. Department of the Treasury (“Treasury”), and the U.S. Department of State (“State”) made several significant announcements regarding recent U.S. government...more
Earlier this month, the Biden Administration formally announced that combating corruption is a core United States national security interest. On June 3, 2021, the Biden Administration issued a Memorandum on Establishing the...more
In the past, sanctioned jurisdictions like Venezuela have embraced virtual currency as a way to bypass channels that involve U.S. dollars, blunting the impact of U.S. economic sanctions policies aimed at isolating those...more
This is the sixth in our start-of-year series examining important trends in white collar law and investigations in the coming year. Our previous entry discussed enforcement by the Massachusetts Attorney General’s Office in...more
Organization Excels at Niche Branding but Stumbles in Avoiding Enforcement - The first paragraph of the press release sums it up: Today the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) took action...more