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SEC Guidance: Disclosure Obligations Stemming from Russia’s Invasion of Ukraine

On May 3, 2022, the SEC’s Division of Corporation Finance (“CorpFin”) issued guidance reminding companies with disclosure obligations under U.S. securities laws to be cognizant of any disclosures that may be warranted as a...more

Banking Bites - May 2022

Welcome to Banking Bites! This is our short summary flagging key developments in the UK that we hope will inform your activities in your market....more

Russia Sanctions Update: Prohibitions Regarding Certain Professional Services, Additional SDN Designations, Visa Restrictions, and...

Following a meeting of G7 leaders on May 8, 2022, the United States enacted additional sanctions and export control measures in response to the ongoing conflict in Ukraine. Among the changes: a prohibition on U.S. persons...more

Congress Votes to Impose Trade Punishments on Russia and Belarus, Will Consider Tax and Procurement Measures

On April 8, 2022, President Biden signed two trade-related bills: one revoking normal tariff treatment for Russia and Belarus, and the other banning Russian energy imports. Following the April recess, Congress may take...more

Russia Sanctions Update: New SDN Designations, Prohibition on New Investment, Expansion of U.S. Export Control Restrictions

The United States has taken further export control and sanctions measures in response to the ongoing conflict in Ukraine. Among the changes: SDN designations of additional persons, entities and vessels, ban on new investment...more

Continued Expansion of U.S. Sanctions, Export Control Measures Against Russia

Expanded Sanctions Authority - As part of the sweeping restrictive measures that the United States has issued in response to the conflict in Ukraine, on March 31, 2022, the U.S. Department of Treasury’s Office of Foreign...more

Medical Industry: Certain Clinical Trials Authorized

On March 24, 2022, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) updated General License 6 of Executive Order (“EO”) 14024 under the Russia Harmful Foreign Activities Sanctions Regulations....more

Additional Sanctions Target the Russian Defense Industry, the Russian State Duma, and more Financial Executives

On March 24, 2022, the United States designated additional parties as sanctions targets in Russia in response to the conflict in Ukraine. Companies should continue to conduct restricted party screening of all parties involved...more

Parties Engaged in Aircraft Serving Activities: Beware

On Friday, March 18, 2022, in response to the continued escalation in Ukraine, the U.S. Commerce Department’s Bureau of Industry and Security (“BIS”) identified both private and commercial aircraft that have flown to Russia...more

U.S. Further Expands Measures Against Russia with Additional Import, Export, Sanctions Restrictions

Last week, the United States continued to impose sweeping restrictive measures in response to the conflict in Ukraine, including measures targeting imports of certain Russian energy and “signature” products into the United...more

Continued Sanctions against Russia and Belarus

On March 2, 2022, in response to the increased escalation in Ukraine, the U.S. Commerce Department’s Bureau of Industry and Security (BIS) imposed new export control measures targeting Belarus for its assistance to Russia...more

Sanctions, COVID and Inflation: Need a Crystal Ball to Update Your Risk Factors?

The Ukraine crisis raises a host of potential forward-looking statement qualifiers and risk factors to consider, as U.S. and European leaders swiftly issued several rounds of progressively more severe sanctions against...more

Round 3: Continued Sanctions Against Russia (and Belarus) - Focus on Russian Banks

In response to the increased escalation in Ukraine, on February 24, 2022, the United States imposed another round of sanctions against Russian financial institutions, state-owned agencies, and Russian elites with close ties...more

U.S. Commerce Department Imposes New Export Control Measures Targeting Russia

As previewed by President Biden in his press conference on February 24, 2022, the U.S. Commerce Department’s Bureau of Industry and Security (BIS) is imposing additional export control measures targeting Russia. The new...more

Round 2: More Sanctions Against Russia

As unveiled during President Biden’s press conference on February 22, 2022, the United States has imposed another round of sanctions in response to President Putin’s decision to deploy troops to the Donetsk People’s Republic...more

U.S. Issues New Round of Sanctions in Response to Rising Tensions in Ukraine

On February 21, 2022, President Biden issued an Executive Order (EO) to impose a first round of sanctions in response to Russian President Putin’s actions with respect to the Donetsk People’s Republic (DNR) and Luhansk...more

Don’t Forget Expansion Under U.S. Export Controls of Restrictions on U.S. Persons

In addition to compliance considerations under US sanctions associated with activities of U.S. persons, companies should also ensure that their compliance programs take into account the expansion under U.S. export controls of...more

OFAC to Companies: Don’t Forget Your U.S. Persons

On September 27, 2021, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of Treasury announced a $1,423,766 settlement with Houston-based supplier, Cameron International Corporation (“Cameron”) to resolve...more

U.S. Imposes Additional Round of Trade Sanctions on Russia

Effective September 7, 2021, the U.S. government imposed a second round of sanctions on Russia in connection with its determination that the Russian Federation violated the Chemical Weapons Convention based on the attack on...more

Russia Now Focal Point of Additional Sanctions and Export Controls, With an Added Bonus for Public Companies (Oh my!)

In response to a variety of activities allegedly undertaken by Russia, the U.S. Government has imposed a series of additional sanctions and export control measures since early March. Collectively, the March and April...more

U.S. Enacts Additional Measures Targeting China

Over the course of this year, the U.S. government has enacted a number of new regulatory changes, including changes aimed at addressing national security concerns related to countries of interest, including China, Russia, and...more

Keeping up with the changes: Has your compliance program been adapted to account for recent changes to U.S. export controls? (Part...

While the pandemic has slowed down many things this year, it did not impede progress by the Department of Commerce’s Bureau of Industry and Security (“BIS”) in publishing various regulatory changes aimed at addressing...more

Exporting Under the EAR? Beware BIS Changes to Military End-Use/Military End-User Restrictions and License Exceptions

In a burst of activity, the US Department of Commerce, Bureau of Industry and Security (BIS) issued two final rules and one proposed rule. These rules, published in the Federal Register on April 28, 2020, made a series of...more

New Sanctions Under Consideration in the Senate

As we discussed in our last alert, Congress has exhibited increased willingness to consider imposing sanctions in order to advance US foreign policy interests. Multiple sanctions-related bills are currently under...more

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