Shrouded within the supplemental emergency appropriations bill for Israel, Ukraine, and Taiwan, the 21st Century Peace through Strength Act passed by Congress and signed into law significantly increases the statute of...more
The recently announced sanctions by the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) sent shockwaves through the Russian financial system, forcing the Moscow Exchange (MOEX) to halt trading of U.S....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
3/7/2024
/ Bureau of Industry and Security (BIS) ,
Due Diligence ,
Economic Sanctions ,
EU ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Financial Institutions ,
Military Conflict ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanction Violations ,
Supply Chain ,
UK ,
Ukraine
Historically, international trade regulation has swung between economic protectionism and national security concerns. Between World War II and the 2018 presidential election, the primary international trade regulatory issue...more
1/22/2024
/ Breach of Contract ,
Bureau of Industry and Security (BIS) ,
CFIUS ,
Directorate of Defense Trade Controls (DDTC) ,
Economic Development ,
Export Administration Regulations (EAR) ,
Foreign Investment ,
Foreign Trade Regulations ,
Foreign Trade Zones ,
Inflation Reduction Act (IRA) ,
International Trade ,
ITAR ,
National Security ,
NATO ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Popular ,
Semiconductors ,
Settlement Agreements ,
Supply Chain ,
United States-Mexico-Canada Agreement (USMCA) ,
Voluntary Disclosure
United States international trade regulatory agencies have updated voluntary self-disclosure (“VSD”) policies and guidance in an effort to incentivize private sector companies and individuals to self-report violations of U.S....more
7/31/2023
/ Arms Export Control Act ,
Bureau of Industry and Security (BIS) ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Export Administration Regulations (EAR) ,
Export Control Reform Act (ECRA) ,
Export Controls ,
False Statements ,
Foreign Agents Registration Act (FARA) ,
Incentives ,
International Emergency Economic Powers Act (IEEPA) ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Self-Disclosure Requirements ,
Self-Reporting ,
U.S. Treasury
On September 30, 2022, the United States instituted new sanctions to address the ongoing Russian-Ukraine conflict. The new sanctions follow the Leaders of the Group of Seven’s (“G7”) statement condemning Russia’s referendum...more
10/19/2022
/ Annexation ,
Bureau of Industry and Security (BIS) ,
Defense Sector ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Exports ,
G7 ,
Military Conflict ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Russia ,
Ukraine
As the war continues in Ukraine, pressure from the European Union (“E.U.”) and the United States (“U.S.”) continue to mount on Russia’s global interests. On April 6, 2022, the United States issued Executive Order 14071,...more
The international community continues to heighten the compliance burden for companies with business ties to Ukraine and Russia following a new round of sanctions. On February 26, 2022, the United States, along with several...more
3/3/2022
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Controls ,
Financial Institutions ,
NYDFS ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
SWIFT ,
Ukraine
As the Russian-Ukraine conflict continues to elicit intensifying economic responses from multiple countries, the frequency and rapidity of these new sanctions have left companies scrambling to align their internal and...more
3/2/2022
/ Bureau of Industry and Security (BIS) ,
Debt Restructuring ,
Economic Sanctions ,
EU ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Supply Chain ,
SWIFT ,
UK ,
Ukraine
As the Russia-Ukraine conflict escalates, the U.S. Government has started to implement new sanctions on Russian entities on top of the ones that already existed. On February 21, 2022, the Executive Order on Blocking Property...more
2/25/2022
/ Biden Administration ,
Executive Orders ,
Exports ,
Foreign Policy ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Russia ,
Sanctions ,
SDN List ,
Supply Chain ,
Ukraine
Many investors, traditional and progressive, are looking hard at cryptocurrency investments as a way to diversify their portfolios. However, there are still multiple known “unknowns” about this new market, including the...more
2/24/2021
/ Anti-Money Laundering ,
Bitcoin ,
Cross-Border Transactions ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Export Controls ,
FinCEN ,
Initial Coin Offering (ICOs) ,
Investment ,
Investment Adviser ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Securities and Exchange Commission (SEC) ,
U.S. Treasury ,
Virtual Currency
On October 1, 2020, the U.S. Treasury’s Office of Foreign Assets Control (OFAC) issued an advisory regarding the potential sanctions risk for entities that facilitate ransomware payments. OFAC defined “ransomware” as:
A form...more
11/19/2020
/ Coronavirus/COVID-19 ,
Cybersecurity ,
Department of Defense (DOD) ,
Department of Health and Human Services (HHS) ,
International Emergency Economic Powers Act (IEEPA) ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
Personal Information ,
Popular ,
Ransomware ,
State Attorneys General ,
Trading with the Enemy Act
The Financial Crimes Enforcement Network (“FinCEN”) and the Office of Foreign Assets Control (“OFAC”) have recently stepped up the pressure on virtual currency companies. Increased regulatory scrutiny has largely taken the...more
Governments in every country are taking international trade compliance seriously. Unlike other company departments that heavily rely on automation to track supply chain compliance, those departments responsible for...more