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BIS Sets Higher KYC Standards for Companies and Universities Over Russia Diversion Concerns

On July 10, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) released new guidance (the “July 10 Release”) outlining different types of precautionary letters (“supplier list” letters, “Project...more

The Emergence of a Global Russia Sanctions Enforcement Regime

The year since Russia’s invasion of Ukraine has been marked by the development of a multi-jurisdictional, multi-agency sanctions regime in the United States, the United Kingdom and the European Union. Although coordination...more

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