News & Analysis as of

Office of Foreign Assets Control (OFAC) Corporate Counsel Export Controls

Morrison & Foerster LLP

OFAC Extends Recordkeeping Requirements from Five to 10 Years; Issues Paperwork Reduction Act Request for Comments

On September 11, 2024, OFAC announced its Interim Final Rule to Extend Recordkeeping Requirements from Five to 10 Years. The Interim Final Rule (IFR) was published in the Federal Register on September 13, 2024. Public...more

Dorsey & Whitney LLP

Biden Administration Again Expands Sanctions on Russia and Its Third Party Supporters

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As Russia continues its war against Ukraine and Ukraine has itself recently opened a new front by capturing Russian territory in its Kursk region, the United States announced on August 23 its latest tranche of sanctions...more

Akin Gump Strauss Hauer & Feld LLP

DOJ Announces First-Ever Corporate Declination Under National Security Division’s Voluntary Self-Disclosure Program

Key Points - On May 21, 2024, the DOJ announced its first ever declination under the NSD’s updated Enforcement Policy, declining to prosecute Sigma-Aldrich Inc., d/b/a MilliporeSigma (a subsidiary of Merck KGaA, Darmstadt,...more

Morrison & Foerster LLP

OFAC Issues Omnibus Accounts Enforcement Case Involving Russia and Other Sanctions Programs

On March 14, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced its first enforcement case of the year and its first ever involving dealings with a Russian designated for sanctions...more

A&O Shearman

U.S. Imposes New Russia Sanctions and Export Controls and Warns of Risk of Continued Business with Russia

A&O Shearman on

On February 23, 2024, the United States imposed its largest number of new sanctions and export control designations against Russia to date—targeting over 600 individuals and entities across a wide swath of the Russian economy...more

Oberheiden P.C.

Insights from OFAC Enforcement Actions So Far

Oberheiden P.C. on

Each year, the Office of Foreign Assets Control (OFAC) initiates several enforcement actions targeting companies, financial institutions, and individuals in the United States and abroad. These enforcement actions can present...more

Fenwick & West LLP

New Official Guidance on Voluntary Self-Disclosure of Trade Control Violations

Fenwick & West LLP on

On July 26, 2023, the U.S. Department of Commerce, Bureau of Industry and Security (BIS), the U.S. Department of the Treasury Office of Foreign Asset Control (OFAC) and the U.S. Department of Justice (DOJ) released joint...more

Fenwick & West LLP

U.S. Government Imposes New Export Controls and Sanctions on Russia and Belarus

Fenwick & West LLP on

On May 19, 2023, the Biden administration announced another major round of U.S. sanctions and export controls against Russia and Belarus in response to the ongoing war in Ukraine, in coordination with the G7 Leaders’ Summit...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

Porter Hedges LLP

Update on Russian-Related Sanctions and Export Controls

Porter Hedges LLP on

As the Russian invasion of Ukraine continues, the executive branch is mounting what the U.S. Department of Treasury (“Treasury”) calls a “historically unprecedented campaign of sanctions and export controls” aimed at...more

Wiley Rein LLP

Biden Administration Toughens Sanctions, Export Controls in Response to Continued Harmful Activities of the Russian Government

Wiley Rein LLP on

On September 15, 2022, the Biden Administration announced a new package of sanctions and export controls to hold the Russian government accountable for its war against Ukraine. ...more

Sheppard Mullin Richter & Hampton LLP

Novel Sanctions Against Business-Related Services Connected to Russia and Additional Export Restrictions

On Sunday, the Department of Treasury’s Office of Foreign Assets Control (OFAC) announced novel and sweeping sanctions on specific categories of services in order to cripple Russia’s wartime capabilities and sanctioned key...more

BakerHostetler

US and Foreign Companies Now Subject to Expansive US License Requirements for Business with Russia

BakerHostetler on

On February 23 and 24, 2022, the United States, through the Department of Commerce’s Bureau of Industry and Security (“BIS”) and the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), took significant...more

American Conference Institute (ACI)

[Complimentary Webinar] Mitigating Sanctions and Export Control Risks for Life Sciences, Research Institutes and Universities -...

Global life sciences companies, research institutes, and universities face unique challenges when complying with U.S. and non-U.S. trade control laws, including complying with general and specific licenses authorizing...more

BCLP

SAP Enforcement Action Underscores Importance of Ensuring Compliance Programs Address Considerations Associated with Business...

BCLP on

On April 29, 2021, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of Treasury, and the Bureau of Industry and Security (“BIS”) of the U.S. Department of Commerce announced settlements with German...more

The Volkov Law Group

SAP Reaches Broad Settlement and Agrees to Pay More Than $8 Million for Violations of Iran Sanctions Program (Part I of IV)

The Volkov Law Group on

In a precedent-setting agreement, the Justice Department, OFAC and the Bureau of Industry and Security announced a settlement with SAP SE for more than $8 million for numerous violations of the Iran Sanctions program....more

American Conference Institute (ACI)

[Virtual Event] Asia Pacific Conference on Economic Sanctions Compliance and Enforcement - May 27th - 28th, 9:00 am - 1:15 pm SGT

ACI’s Asia-Pacific Advanced Conference on Economic Sanctions Compliance and Enforcement is the largest sanctions gathering in Asia for financial institutions and global exporters. This unique conference features senior...more

Society of Corporate Compliance and Ethics...

[Virtual Event] 2021 Middle East and Africa Regional Compliance & Ethics Conference - February 11th, 8:55 am - 2:00 pm GST

Our Virtual Regional Compliance Conferences provide updates on the latest news in regulatory requirements, compliance enforcement, and strategies to develop effective compliance programs. Watch, listen, and ask questions from...more

Akin Gump Strauss Hauer & Feld LLP

Reminder Regarding the Jurisdictional Reach and Limits of U.S. Export Control, Sanctions, and Foreign Investment Regulations

United States export control, sanctions, and foreign investment (CFIUS) regulations advance U.S. national security and foreign policy interests, but in very different ways. They are also quite complex. As a result, media...more

Foley Hoag LLP - White Collar Law &...

White Collar Year in Preview: Sanctions/Export Controls Trends in 2020

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

A&O Shearman

DOJ Offers Non-Prosecution Agreements And No-Fines For Self-Reporting Export Control And Sanctions Violations

A&O Shearman on

In a development that could significantly affect how companies deal with possible export control and sanctions violations, the Department of Justice (“DOJ”) recently revised its policy regarding voluntary disclosure of trade...more

Akin Gump Strauss Hauer & Feld LLP

DOJ Provides Additional Incentives for Voluntary Self-Disclosures of Criminal Export Controls and Sanctions Violations

• On December 13, 2019, the Department of Justice (DOJ) revised and re-issued its “Export Controls and Sanctions Policy for Business Organizations” (the “Revised Policy”) to “provide greater clarity for companies faced with a...more

Faegre Drinker Biddle & Reath LLP

Important New Guidance for Companies Considering Voluntary Disclosures of Export Control and Sanctions Violations

On December 13, 2019, the U.S. Department of Justice’s National Security Division (NSD) issued important new policy guidance regarding voluntary disclosures of export control and sanctions laws violations. Among other things,...more

ArentFox Schiff

US Administration Tests the Water on New Unheard-of Government Review of International Technology Transactions

ArentFox Schiff on

Under this new evaluation process, Commerce can prohibit companies from engaging in a wide variety of transactions and order them to cease using the information technology or telecommunication system in question even if it is...more

Morrison & Foerster LLP

Sanctions Enforcement Tips from Former OFACers

Morrison & Foerster’s National Security practice provides strategic advice and counseling to clients on a broad range of challenging regulatory and compliance matters in the national security space. In advising clients, the...more

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