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
6/7/2024
/ Bureau of Industry and Security (BIS) ,
Corporate Counsel ,
Department of Justice (DOJ) ,
Directorate of Defense Trade Controls (DDTC) ,
Enforcement ,
Export Controls ,
Incentives ,
National Security ,
Non-Prosecution Agreements ,
Office of Foreign Assets Control (OFAC) ,
Sanction Violations ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
White Collar Crimes
Key Points -
On January 16, 2024, Matthew Axelrod, Assistant Secretary for Export Enforcement at the U.S. Department of Commerce’s BIS announced key updates to BIS’s VSD process. The updates are also now reflected on BIS’s...more
1/26/2024
/ Bureau of Industry and Security (BIS) ,
Enforcement ,
Export Administration Regulations (EAR) ,
Exports ,
National Security ,
Negligence ,
Non-Prosecution Agreements ,
Penalties ,
Penalty Reductions ,
Self-Disclosure Requirements ,
U.S. Commerce Department ,
Voluntary Disclosure
Key Points -
On October 18, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) took action to relax certain U.S. sanctions on Venezuela in response to the signing of an electoral roadmap...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
8/7/2023
/ Anti-Corruption ,
Bureau of Industry and Security (BIS) ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Export Controls ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Sanction Violations ,
U.S. Commerce Department ,
U.S. Treasury ,
Voluntary Disclosure
Key Points -
On March 30, 2023, OFAC announced a settlement agreement with Wells Fargo for 124 apparent violations of three different sanctions programs (Iran, Syria and Sudan), all related to a legacy Wachovia Bank...more
4/18/2023
/ Compliance ,
Corporate Counsel ,
Corporate Culture ,
Corporate Misconduct ,
Economic Sanctions ,
Enforcement Actions ,
Financial Transactions ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Sanction Violations ,
Wells Fargo
Introduction -
In 2022, the United States, European Union (EU) and United Kingdom, along with a significant number of other partners and allies, imposed an unprecedented number of economic, financial and trade sanctions...more