U.S. sanctions enforcement is evolving to adopt a “control” analysis similar to the analysis employed by the European Union and United Kingdom based on a recent major enforcement action by the U.S. Department of the...more
The President has issued three executive orders that impose universal tariffs on Mexico, Canada, and China, deploying IEEPA in a sweeping manner to address the President’s declaration of a national emergency regarding illegal...more
2/4/2025
/ Canada ,
China ,
Customs and Border Protection ,
Economic Sanctions ,
Executive Orders ,
Foreign Policy ,
Imports ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Mexico ,
National Security ,
Tariffs ,
Trade Relations ,
Trade Retaliation
On 12 September 2024, the UK Government published The Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024 (“the Regulations”), which provide the regulatory framework for the Office of Trade Sanctions...more
9/26/2024
/ Criminal Liability ,
ECJU ,
Economic Sanctions ,
Enforcement ,
HMRC ,
New Regulations ,
Office of Financial Sanctions Implementation (OFSI) ,
Penalties ,
Prison ,
Russia ,
Security Breach ,
Trade Relations ,
UK
As discussed in our May 7, 2024 alert, on April 24, 2024, President Biden signed into law a foreign military support package (i.e., H.R. 815), which included a provision doubling the statute of limitations (“SOL”) from five...more
9/24/2024
/ Civil Monetary Penalty ,
Cuban Assets Control Regulations (CACR) ,
Department of Labor (DOL) ,
Economic Sanctions ,
Enforcement ,
Interim Final Rules (IFR) ,
International Emergency Economic Powers Act (IEEPA) ,
Investigations ,
Office of Foreign Assets Control (OFAC) ,
Recordkeeping Requirements ,
Regulatory Requirements ,
Statute of Limitations ,
TWEA
Creates A New Forced Labor “Presumption” That Would Prohibit Certain Imports From Entry Into The United States, Among Other Measures, To Address Forced Labor In China -
On December 23, 2021, President Biden signed into law...more
1/14/2022
/ China ,
Clean Energy ,
Customs and Border Protection ,
Economic Sanctions ,
Forced Labor ,
Human Rights ,
Imports ,
Semiconductors ,
Supply Chain ,
Trade Facilitation and Trade Enforcement Act ,
Unruh Civil Rights Act ,
Uyghur Forced Labor Prevention Act (UFLPA) ,
Withhold Release Orders (WROs)
OFAC Provides Guidance on the Essential Components of a Risk-Based Sanctions Compliance Program -
On May 2, 2019, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of the Treasury issued guidelines...more
5/6/2019
/ Audits ,
Bank Secrecy Act ,
Compliance ,
Economic Sanctions ,
Employee Training ,
Internal Controls ,
Office of Foreign Assets Control (OFAC) ,
Patriot Act ,
Risk Assessment ,
Sanction Violations ,
U.S. Treasury
Stepping outside of SWIFT -
Since its inception more than a decade ago, cryptocurrency has been viewed as a way to supplant traditional global methods of exchanging money. Today, as virtual currencies proliferate,...more
2/19/2019
/ Corruption ,
Cryptocurrency ,
Digital Currency ,
Economic Sanctions ,
Initial Coin Offering (ICOs) ,
International Emergency Economic Powers Act (IEEPA) ,
Iran ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
SDN List ,
Securities and Exchange Commission (SEC) ,
Self-Regulatory Organizations ,
SWIFT ,
Virtual Currency
This Enforcement Action Underscores The Risks Of Sourcing Products Without Comprehensive Supply Chain Due Diligence -
On January 31, 2019, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of the Treasury...more
2/8/2019
/ China ,
Cosmetics ,
Due Diligence ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Exports ,
Goods or Services ,
Imports ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Supply Chain
On May 8, 2018, President Donald Trump announced that the United States was withdrawing from the Joint Comprehensive Plan of Action (“JCPOA”) negotiated between the “P5+1” countries (United States, United Kingdom, France,...more
On August 24, 2017, President Trump issued Executive Order 13808 (“E.O. 13808” or the “Executive Order”) titled “Imposing Additional Sanctions With Respect to the Situation in Venezuela.” The Executive Order prohibits certain...more
On 1 September 2016, the US Department of the Treasury's Office of Foreign Assets Control (OFAC) supplemented sanctions against Russia imposed in connection with the conflict in Eastern Ukraine with names of a number of...more