Episode 324 -- Third-Party Risks and Sanctions Compliance
FINCast Ep. 39 – State of Russia Sanctions Two Years After the Invasion
Understanding the Additional Risks When Making a Ransomware Payment
Looking The Other Way: Recent Cases Of AML And Sanctions Failings In Scandinavia
Episode 118 -- Update on OFAC Enforcement and Lessons Learned
As the interplay between export controls, trade sanctions, and anticorruption enforcement continues to intensify, multinational companies must remain vigilant in ensuring that their compliance programs address the many...more
We all know what a “core” sanctions violation looks like. The heartland of such misconduct has been described on numerous occasions in OFAC enforcement actions and settlements. In this environment, however, companies have...more
Implications Related to the Doubling of the Statute of Limitations for Civil and Criminal Violations of Two Primary Sanctions Authorities - SUMMARY - On April 24, 2024, President Biden signed into law a foreign military...more
The U.S. Government recently announced the largest round of sanctions against the Russian Federation (Russia) since the invasion of Ukraine two years ago. This multi-agency effort enacted over 500 sanctions against foreign...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
On 6 November 2023, the Department of the Treasury’s Financial Crimes Enforcement Network and the Department of Commerce’s Bureau of Industry and Security issued a joint notice concerning a new Suspicious Activity Report key...more
Over the last several months, companies have become entangled in an increasingly complex web of new and expanded sanctions and export control restrictions related to Russia in response to its war on Ukraine. The current...more
Under the U.S. Export Administration Regulations (EAR), Part 736 General Prohibition #5 (EAR 736.5) imposes restrictions on certain activities related to exports, reexports, and transfers (in-country) of items subject to the...more
On April 19, 2023, the US Department of Commerce Bureau of Industry and Security (BIS) entered into a settlement agreement wherein Seagate Technology LLC and Seagate Singapore International Headquarters Pte. Ltd....more
Matt Axelrod, the Assistant Secretary for Export Enforcement, at the Bureau of Industry and Security (“BIS”) of the U.S. Department of Commerce, must be grinning with satisfaction that BIS delivered, in a big way, after he...more
The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and...more
Civil and criminal penalties levied against U.S. companies for trade violations are just the beginning of the potential unforeseen costs of doing business in the global marketplace. What cannot be quantified are the countless...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
As trade compliance gains more traction, US regulators have made it clear that having compliance policies in place is critical, regardless of the company size or the industry. The implementation of such compliance programs...more
• President Donald Trump saying at the recent G20 Summit in Japan that American companies could keep selling products to Huawei Technologies Co. Ltd. (Huawei) was another installment in the drama surrounding the Chinese tech...more
ANTICORRUPTION DEVELOPMENTS - $34 Million SEC Settlement for Legg Mason - On August 27, 2018, the Securities and Exchange Commission (SEC) announced that Legg Mason Inc. will pay more than $34 million to settle an...more
• On June 11th, BIS published a superseding settlement agreement with ZTE, levying the largest-ever monetary penalty by BIS against a non-U.S. company and imposing significant additional compliance measures in exchange for...more
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