On June 30, President Trump signed Executive Order 14312, “Providing for the Revocation of Syria Sanctions” (EO), which formally terminates many U.S. sanctions on Syria. Public reports indicate that the European Union has...more
On May 23, 2025, the U.S. Treasury Department, Office of Foreign Assets Control (OFAC) announced several actions to provide sanctions relief to Syria. OFAC is the primary government agency responsible for administering U.S....more
On February 21, the Trump Administration released the America First Investment Policy (the memo or memorandum). The wide-ranging memo formally targets investment from the People’s Republic of China, including Hong Kong and...more
3/3/2025
/ CFIUS ,
China ,
Critical Infrastructure Sectors ,
Executive Orders ,
Foreign Investment ,
International Trade ,
Investment ,
Legislative Agendas ,
National Security ,
Regulatory Agenda ,
Technology Sector ,
Trump Administration
In the roughly four weeks since his inauguration, President Trump has announced then paused tariffs on Canada and Mexico, expanded tariffs on steel and aluminum, and suggested introducing reciprocal tariffs on the rest of the...more
You are reading the December 2024 Update of the Bass, Berry & Sims Enforcement Roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox.
- An...more
1/13/2025
/ Compliance ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
International Trade ,
International Trade Commission (ITC) ,
Regulatory Agenda ,
Regulatory Reform ,
Securities and Exchange Commission (SEC) ,
Trade Relations ,
U.S. Commerce Department
You are reading the Summer 2024 Update of the Bass, Berry & Sims Enforcement Roundup. After a short hiatus, we are back to reporting on notable enforcement actions and policy changes and providing a bit of our insight.
-...more
9/6/2024
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Cryptocurrency ,
Economic Sanctions ,
Enforcement ,
Export Controls ,
Foreign Investment ,
International Trade ,
Investors ,
NPRM ,
Russia ,
Technology Sector ,
Uyghur Forced Labor Prevention Act (UFLPA)
You are reading the April 2024 Update of the Bass, Berry & Sims Enforcement Roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox.
April saw...more
5/9/2024
/ Bureau of Industry and Security (BIS) ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Export Controls ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Self-Disclosure Requirements ,
U.S. Commerce Department ,
Voluntary Disclosure
On April 11, the U.S. Treasury Department promulgated a Notice of Proposed Rulemaking (NPRM) amending the regulations that govern the operations of the Committee on Foreign Investment in the United States (CFIUS) to increase...more
You are reading the March 2024 Update of the Bass, Berry & Sims Enforcement Roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox.
Overview...more
January saw continuing focus on Russia. First, the Commerce Department’s Bureau of Industry and Security (BIS) expanded export controls on certain goods for Russia and Belarus. Second, a U.S.-Israeli citizen was arrested for...more
2/8/2024
/ Bureau of Industry and Security (BIS) ,
China ,
Department of Justice (DOJ) ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
International Trade ,
Office of Foreign Assets Control (OFAC) ,
Securities and Exchange Commission (SEC) ,
Self-Disclosure Requirements ,
U.S. Commerce Department ,
U.S. Treasury ,
United Arab Emirates (UAE)
December saw continuing enforcement actions involving Russia. First, the Treasury Department’s Office of Foreign Assets Control (OFAC) settled investigations into apparent sanctions violations by a New York-based insurance...more
1/10/2024
/ Commodities ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Financial Institutions (FFI) ,
International Trade ,
Maritime Transport ,
Office of Foreign Assets Control (OFAC) ,
Regulatory Agenda ,
Regulatory Reform ,
Russia ,
Sanction Violations ,
U.S. Commerce Department ,
U.S. Treasury
You are reading the November 2023 Update of the Bass, Berry & Sims Enforcement Roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your...more
12/8/2023
/ Bureau of Industry and Security (BIS) ,
Cryptocurrency ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Entity List ,
Export Controls ,
FinCEN ,
Foreign Corrupt Practices Act (FCPA) ,
International Trade ,
NGOs ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Russia ,
Sanction Violations ,
U.S. Treasury
September saw a number of enforcement actions involving Iran. First, the Office of Foreign Assets Control (OFAC) announced separate settlements with 3M and Emigrant Bank for violations of the Iranian Transactions and...more
10/11/2023
/ Bureau of Industry and Security (BIS) ,
Department of Homeland Security (DHS) ,
Foreign Corrupt Practices Act (FCPA) ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Iran ,
ITSR ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Securities and Exchange Commission (SEC) ,
Uyghur Forced Labor Prevention Act (UFLPA)
The U.S. government continues to aggressively monitor and impose restrictions on transactions deemed to threaten U.S. national security.
On a day-to-day basis, restrictions arise most commonly in the context of export...more
On July 26, the Department of Commerce, Department of the Treasury, and Department of Justice released a Tri-Seal Compliance Note (July Note) providing guidance on voluntary self-disclosure of potential violations of U.S....more
8/1/2023
/ CFIUS ,
Compliance ,
Department of Justice (DOJ) ,
Disclosure ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Exports ,
International Trade ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Policies and Procedures ,
Self-Disclosure Requirements ,
U.S. Commerce Department ,
U.S. Treasury ,
Voluntary Disclosure
May saw several Russia-related enforcement and other actions. The Department of Justice (DOJ) identified and charged three foreign nationals with violating export control laws as they attempted to circumvent Russian...more
6/23/2023
/ Arms Export Control Act ,
Bureau of Industry and Security (BIS) ,
China ,
Department of Justice (DOJ) ,
Enforcement ,
Entity List ,
EU ,
Export Controls ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Iran ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Trade Secrets ,
U.S. Commerce Department
You are reading the April 2023 Update of the Bass, Berry & Sims Enforcement Roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox.
-We saw...more
5/25/2023
/ China ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
International Trade ,
Iran ,
North Korea ,
Russia