In November 2024, in the first successful private cause of action under the Anti-Foreign Sanctions Law (AFSL), a Chinese court adjudicated a civil claim by a Chinese company against its overseas customer for failure to pay...more
6/5/2025
/ Breach of Contract ,
China ,
Contract Disputes ,
Dispute Resolution ,
Economic Sanctions ,
Enforcement Actions ,
International Arbitration ,
International Trade ,
Jurisdiction ,
Office of Foreign Assets Control (OFAC) ,
SDN List
On January 10, 2025, China’s State Administration for Market Regulation (“SAMR”) put into effect its Compliance Guidelines for Healthcare Companies to Prevent Commercial Bribery Risks (“Compliance Guidelines”)....more
2/12/2025
/ Anti-Corruption ,
China ,
Clinical Laboratories ,
Compliance ,
Corporate Governance ,
Corruption ,
Enforcement Actions ,
Fraud ,
Health Care Providers ,
Healthcare ,
Healthcare Fraud ,
Medical Research ,
Pharmaceutical Industry ,
Regulatory Agenda ,
Regulatory Requirements ,
Risk Management
On October 11, 2024, China’s State Administration for Market Regulation (“SAMR”) issued the Draft Compliance Guidelines for Healthcare Companies to Prevent Commercial Bribery Risks (“Draft Guidelines”). These guidelines...more
As peak summer holiday season approaches, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) continues to remind the private sector of the importance of strict economic sanctions compliance. OFAC...more
7/15/2021
/ Corporate Counsel ,
Department of Justice (DOJ) ,
Digital Currency ,
Economic Sanctions ,
Enforcement Actions ,
Foreign Exchanges ,
ITSR ,
Moneygram ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
U.S. Treasury
As we previously wrote in our OFAC 2020 Year in Review, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) saw a drop in enforcement activity in 2020, likely due to the massive year it had in 2019 and...more
2/18/2021
/ Audits ,
Citizenship ,
Compliance ,
Corporate Counsel ,
Enforcement Actions ,
Foreign Subsidiaries ,
Information Technology ,
Licenses ,
Nexus ,
Office of Foreign Assets Control (OFAC) ,
Remediation ,
Sanctions
In too many ways to count, 2020 was an extraordinary year. As we move into 2021 with optimism for an end to the pandemic and better days ahead, we understand that the activity last year of the U.S. Department of the...more
2/16/2021
/ China ,
Corporate Counsel ,
Cuban Assets Control Regulations (CACR) ,
Customs and Border Protection ,
Department of Homeland Security (DHS) ,
Economic Sanctions ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Exports ,
Foreign Financial Institutions (FFI) ,
Iran Sanctions ,
Maritime Transport ,
NDAA ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Pentagon ,
Pipelines ,
Popular ,
Ransomware ,
Russia ,
SDN List ,
Trump Administration
China has recently introduced unreliable entity list ("Entity List") regulations to provide a framework for China's upcoming list of economic sanctions. As early as October 2018 and March 2020, China has implemented "blocking...more
10/12/2020
/ China ,
Criminal Investigations ,
Enforcement Actions ,
Entity List ,
Foreign Entities ,
Huawei ,
MInistry of Commerce ,
Office of Foreign Assets Control (OFAC) ,
Sanctions ,
U.S. Commerce Department ,
U.S. Treasury ,
US Department of State