Key Takeaways:
• U.S. imposes additional sanctions on Russian elites, along with their family members, companies, and personal vehicles
• Actions targeting the defense sector and Russian government-affiliated media...more
3/8/2022
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Executive Orders ,
Export Controls ,
Financial Transactions ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
SWIFT ,
Ukraine
On February 28, 2022, the U.S. government announced new sanctions on the Central Bank of Russia, National Wealth Fund, Ministry of Finance, and Russian Direct Investment Fund, dramatically increasing the economic impact of...more
3/2/2022
/ Biden Administration ,
Economic Sanctions ,
Enforcement Priorities ,
Executive Orders ,
Export Controls ,
Financial Transactions ,
Foreign Currency ,
Foreign Trade Regulations ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Ukraine
As we had reported in our earlier client alert and 2022 Year in Preview, Russia’s invasion of Ukraine has resulted in a new wave of sanctions and export controls on Russia, including sanctions on key sectors of the Russian...more
2/28/2022
/ Australia ,
Canada ,
China ,
Economic Sanctions ,
EU ,
Export Controls ,
Exports ,
Financial Institutions ,
Financial Services Industry ,
Japan ,
Licensing Rules ,
New Zealand ,
Russia ,
SDN List ,
Sovereign Debt ,
UK ,
Ukraine ,
Vladimir Putin
This is the fifth post in this year’s series examining important trends in white collar law and investigations. Our previous post discussed trends in State AG enforcement. Up next: SEC Enforcement in 2022: A Look Ahead. ...more
2/25/2022
/ Afghanistan ,
Belarus ,
Biden Administration ,
Bureau of Industry and Security (BIS) ,
Burma ,
Cambodia ,
CFIUS ,
China ,
Cuba ,
Economic Sanctions ,
Enforcement ,
Ethiopia ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Human Rights ,
International Criminal Court ,
Iran Sanctions ,
ITAR ,
Joint Comprehensive Plan of Action (JCPOA) ,
Myanmar ,
Nicaragua ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
SDN List ,
Securities and Exchange Commission (SEC) ,
Sudan ,
U.S. Treasury ,
Uyghur Forced Labor Prevention Act (UFLPA) ,
Venezuela ,
Virtual Currency ,
Withhold Release Orders (WROs)
For months, the Biden administration and the governments of U.S. allies around the world have raised concerns about Russian actions in the region. In the same breath, those governments have warned of massive, coordinated...more
2/18/2022
/ Aerospace ,
Banking Sector ,
Banks ,
Belarus Sanctions ,
Biden Administration ,
China ,
Economic Sanctions ,
Energy Sector ,
EU ,
Export Controls ,
Foreign Direct Product Rule ,
Investment Controls ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
SWIFT ,
UK ,
Ukraine
The U.S Department of the Treasury’s Office of Foreign Assets Control (OFAC) has published guidance to aid members of the virtual currency industry (ranging from tech companies to brokers to users) in complying with OFAC...more
Huawei Charged in Racketeering Conspiracy and Conspiracy to Steal Trade Secrets; Temporary General License Extended –
On February 13, 2020, Huawei Technologies Co. Ltd. (Huawei) and two of its U.S. subsidiaries were...more
3/17/2020
/ Airbus ,
Bureau of Industry and Security (BIS) ,
Compliance ,
Criminal Conspiracy ,
Criminal Prosecution ,
Cross-Border ,
Cross-Border Transactions ,
Economic Sanctions ,
General Licenses ,
Huawei ,
Iran ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
Transitional Arrangements ,
U.S. Treasury ,
UK ,
UK Brexit ,
Venezuela
New CFIUS Regulations Released: Final Rules Impact Foreign Investment in Technology, Infrastructure, and Data (TID) Businesses and Real Estate -
On January 13, 2020, the Department of the Treasury issued final regulations...more
2/6/2020
/ Artificial Intelligence ,
Bureau of Industry and Security (BIS) ,
CFIUS ,
Critical Infrastructure Sectors ,
Cross-Border Transactions ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Investment ,
Office of Foreign Assets Control (OFAC) ,
Technology Sector
This is the sixth in our start-of-year series examining important trends in white collar law and investigations in the coming year. Our previous entry discussed enforcement by the Massachusetts Attorney General’s Office in...more
1/24/2020
/ Bureau of Industry and Security (BIS) ,
Chief Compliance Officers ,
China ,
Compliance ,
Corporate Counsel ,
Cuba ,
Customs and Border Protection ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Entity List ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Hong Kong ,
Huawei ,
Human Rights ,
Information Technology ,
Iran Sanctions ,
Magnitsky Act ,
National Security ,
New Guidance ,
New Regulations ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Software ,
Syria ,
Technology Sector ,
Turkey ,
U.S. Treasury ,
US Department of State ,
Venezuela ,
Voluntary Disclosure ,
White Collar Crimes
DOJ Issues Revised Export Control and Sanctions Enforcement Policy for Business Organizations Providing Clear Guidance on the Benefits of Self-Disclosing Violations -
On December 13, 2019, the Department of Justice (DOJ)...more
In December, the Department of Justice (DOJ) announced the release of a new policy for business organizations regarding voluntary self-disclosures of export control and sanctions violations. The new Policy makes explicit that...more
Alert for Information and Communications Technology and Services Industries: Proposed New Rule Implements Unprecedented Regime to Review and Restrict Transactions -
The Department of Commerce (DOC) is accepting comments...more
Additional Restrictions on Exports to Cuba -
On October 15, 2019, the Department of Commerce (DOC) amended the Export Administration Regulation (EAR) to further restrict the export and reexport of items to Cuba. The...more
11/25/2019
/ CFIUS ,
Compliance ,
Cross-Border Transactions ,
Cuba ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Exports ,
Foreign Investment ,
Human Rights ,
Magnitsky Act ,
Withhold Release Orders (WROs)
On May 2, 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) released “A Framework for OFAC Compliance Commitments.” This Framework provides guidance for the creation of an effective...more