News & Analysis as of

Office of Foreign Assets Control (OFAC) Software Bureau of Industry and Security (BIS)

Lowenstein Sandler LLP

New Prohibitions on Providing SaaS Services to Russia

In line with Group of Seven (G7) efforts to disrupt the Russian military-industrial base’s reliance on foreign IT systems, in June 2024 the U.S. Department of Commerce and the Department of the Treasury jointly issued new...more

Lowenstein Sandler LLP

Trade Matters - Lowenstein Sandler's Global Trade & National Security Newsletter - JULY 12, 2024

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On June 20, the Department of Commerce’s Bureau of Industry and Security (BIS) for the first time banned a software and cybersecurity company using authority provided by June 2023’s “Protecting Americans’ Sensitive Data from...more

Holland & Knight LLP

Commerce Department: Final Determination of Russia-Backed Cybersecurity, Antivirus Software

Holland & Knight LLP on

The U.S. Department of Commerce's Office of Information and Communications Technology and Services (OICTS) within the Bureau of Industry and Security (BIS) issued a Final Determination on June 20, 2024, pursuant to Executive...more

Mayer Brown

BIS Issues First ICTS Ban, Prohibiting Sales and Updates to Kaspersky Products and Services in the US, while OFAC Sanctions Senior...

Mayer Brown on

On June 20, 2024, the Department of Commerce's Bureau of Industry and Security (BIS) issued a Final Determination (“Determination”) prohibiting Kaspersky Lab, Inc.—the US subsidiary of the Russia-based antivirus software and...more

Wiley Rein LLP

New U.S. Sanctions and Export Controls on Russia Target Foreign Financial Institutions, Business Software, Critical Industries

Wiley Rein LLP on

The Biden Administration’s recent expansion of sanctions and export controls to counter Russian aggression will impact non-U.S. financial institutions and increase compliance risks for the business software sector and other...more

Sheppard Mullin Richter & Hampton LLP

Now Including the Kitchen Sink: Expansion of Export Controls on Russia Adds Restrictions on Low-Level Items and Software

Last year, we published an update on BIS’s foray into prohibiting EAR99 items for export to Russia and Belarus. We noted (somewhat in jest) that kitchen sinks may one day be added. Well, that day has come. Stainless steel...more

Dechert LLP

U.S. Sanctions Russian Financial Infrastructure

Dechert LLP on

On the eve of the 2024 Group of Seven (G7) Leaders’ Summit, the United States imposed new sanctions and export control measures against Russia further targeting sanctions evaders and, for the first time, the Russian...more

K2 Integrity

Sanctions Against Russia: U.S. Increases Secondary Sanctions Risks for Foreign Financial Institutions, Expands Sanctions and...

K2 Integrity on

On 12 June 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued new measures to further isolate Russia’s...more

ArentFox Schiff

US Government Throws “Kitchen Sink” Export Controls at Russia, Plus Sweeping EAR99 Software Controls, and IT and Software Services...

ArentFox Schiff on

Three US agencies – the US Department of Commerce, Bureau of Industry and Security (BIS), the US Department of the Treasury, Office of Foreign Assets Control (OFAC), and the US Department of State – took new actions on June...more

Fenwick & West LLP

U.S. Imposes Sweeping New Sanctions and Export Controls on Russia and Belarus, including on Certain Software and Related Services

Fenwick & West LLP on

Citing Russia’s “transition to a full war economy,” the United States imposed sweeping new sanctions and export controls on Russia and Belarus today, including companies and individuals that continue to supply Russia’s...more

Lowenstein Sandler LLP

Trade Matters - Lowenstein Sandler's Global Trade & National Security Newsletter - February 14, 2024

Lowenstein Sandler LLP on

Teradyne, a Massachusetts-based supplier of semiconductor testing equipment, has reportedly pulled $1 billion of manufacturing equipment out of China in 2023 following export controls on advanced computing materials and...more

Foley Hoag LLP

The Voluntary Disclosure Landscape After Microsoft’s Settlements with BIS and OFAC and the Issuance of the Axelrod Memorandum

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On April 6, 2023, Microsoft Corporation (“Microsoft”) agreed to pay $3.3 million to the Department of Commerce’s Bureau of Industry and Security (“BIS”) and the Department of the Treasury’s Office of Foreign Assets Control...more

Torres Trade Law, PLLC

OFAC and BIS Announce Microsoft Settlement of Sanctions and Export Control Violations

Torres Trade Law, PLLC on

On April 6, 2023, the Department of Treasury Office of Foreign Assets Control (“OFAC”) and the Department of Commerce Bureau of Industry and Security (“BIS”) announced a settlement with Microsoft Corporation (“Microsoft”) and...more

The Volkov Law Group

Microsoft Pays OFAC and BIS Over $3.3 Million for Violations of Multiple Sanctions Programs (Part I of II)

The Volkov Law Group on

OFAC announced only one settlement in the first three months of 2023.  Given its ongoing role in the implementation and enforcement of Russia Sanctions, OFAC’s enforcement record so far is completely understandable.  The...more

K2 Integrity

Sanctions Against Russia: The Week in Review - April 2022 - 2

K2 Integrity on

The Week in Review delivers the impact and analysis for the public, private, and non-profit sectors from our regular reporting of the evolving global sanctions campaign against Russia. This week, we reviewed the recent...more

Wiley Rein LLP

Treasury, Commerce Target Russia’s Tech Sector, Defense Industrial Base

Wiley Rein LLP on

On March 31, 2022, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) imposed sanctions on 21 entities and 13 individuals “as part of its crackdown on the Kremlin’s sanctions evasion networks and...more

Dorsey & Whitney LLP

United States Imposes More Sanctions to Block Russian Access to U.S. Banking System and U.S. Goods, Technology or Software

Dorsey & Whitney LLP on

On February 24, 25 and 28, the United States broadened its economic sanctions against Russia in response to its full-scale military invasion of Ukraine. As the Biden Administration had promised in recent weeks, in close...more

Lowenstein Sandler LLP

Trade Matters - October 2021

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1. Expanded Export Controls on Certain Biological Equipment Software Are Coming- As part of the Bureau of Industry and Security’s emerging and foundational technology control effort, new export controls are forthcoming...more

Lowenstein Sandler LLP

Trade Matters - Lowenstein Sandler's Global Trade & Policy Newsletter - June 2021

1. Recent Enforcement: Even Companies That Invest in Compliance Pay Penalties- Since our April enforcement roundup, the Office of Foreign Assets Control (OFAC) and the Bureau of Industry and Security (BIS) in the Department...more

Foley Hoag LLP - White Collar Law &...

Lessons to Learn for Global Software Providers from SAP Settlements of DOJ, BIS and OFAC Investigations Concerning Software...

Sales of your software are robust around the globe. You have a network of third-party resellers, distributors or implementation partners that are driving international growth. Your customers praise your efficient maintenance...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

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

Skadden, Arps, Slate, Meagher & Flom LLP

"US Announces Record-Setting Penalties for Violations of Export Controls and Economic Sanctions"

On March 7, 2017, the United States announced that China’s Zhongxing Telecommunications Equipment Corporation and ZTE Kangxun Telecommunications Ltd. and their respective affiliates (collectively, ZTE) had agreed to a record...more

Davis Wright Tremaine LLP

Cuba Si! Trade With Cuba … Not Quite Yet

There has been much fanfare surrounding the reestablishment of diplomatic relations with Cuba, starting with President Obama’s announcement of the resumption of bilateral relations, and followed by the formal establishment of...more

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