The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and...more
The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and...more
7/8/2022
/ Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Financial Transactions ,
FinCEN ,
General Licenses ,
Gold ,
Imports ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Trade Restrictions ,
Ukraine
The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and...more
6/7/2022
/ Belarus ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Enforcement ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Final Rules ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Transparency ,
Ukraine
The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and...more
The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and...more
5/6/2022
/ Aircraft ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Prohibited Transactions ,
Russia ,
U.S. Commerce Department ,
Ukraine
The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and...more
...President Biden Extends National Emergency under Executive Order 14024 -
On April 13, President Biden extended the national emergency declared under Executive Order (EO) 14024 for an additional year due to the harmful...more
4/19/2022
/ Belarus ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Financial Institutions ,
Joe Biden ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
U.S. Commerce Department ,
Ukraine
The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and...more
4/12/2022
/ Belarus Sanctions ,
Biden Administration ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Direct Product Rule ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Ukraine
The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and...more
4/6/2022
/ Belarus Sanctions ,
Biden Administration ,
Economic Sanctions ,
Executive Orders ,
Export Controls ,
Foreign Trade Regulations ,
General Licenses ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Ukraine
The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes the evolving situation as of...more
The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes the evolving situation as of...more
The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes the evolving situation as of...more
3/15/2022
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Financial Institutions ,
Foreign Investment ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Ukraine
This UPDATED post summarizes the situation as of late evening on Monday, March 7, concerning current U.S. sanctions and export restrictions related to Russia and Ukraine...more
3/8/2022
/ Belarus ,
Economic Sanctions ,
Export Controls ,
Foreign Direct Investment ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
South Korea ,
U.S. Commerce Department ,
Ukraine
This UPDATED post summarizes the situation as of late evening on Thursday, March 3, concerning current U.S. sanctions and export restrictions related to Russia and Ukraine...more
3/4/2022
/ Asset Freeze ,
Belarus Sanctions ,
Departments of Commerce ,
Economic Sanctions ,
Entity List ,
Export Controls ,
Final Rules ,
Foreign Direct Investment ,
Foreign Relations ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Ukraine
This UPDATED post summarizes the situation as of late evening on Monday, February 28, concerning current U.S. sanctions and export restrictions related to Russia and Ukraine. This post supplements our post of late evening on...more
3/1/2022
/ Asset Freeze ,
Banks ,
Biden Administration ,
Economic Sanctions ,
Executive Orders ,
Export Controls ,
Exports ,
Financial Institutions ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SWIFT ,
Ukraine
This UPDATED post summarizes the situation as of late evening on Friday, February 25, concerning current U.S. sanctions and export restrictions related to Russia and Ukraine. This post supplements our post of late evening on...more
2/28/2022
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Controls ,
Exports ,
Licensing Rules ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
U.S. Commerce Department ,
Ukraine ,
Vladimir Putin
This UPDATED post summarizes the situation as of late evening on Thursday, February 24, concerning current U.S. sanctions and export restrictions related to Russia and Ukraine. This supplements our post of late evening on...more
On February 22, President Biden issued Executive Order14,024 (the EO), which authorizes the U.S. Treasury Department, Office of Foreign Assets Control (OFAC) to designate Russian and other entities and individuals involved in...more
2/24/2022
/ Biden Administration ,
Economic Sanctions ,
Executive Orders ,
Exports ,
Financial Institutions ,
Foreign Policy ,
Imports ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Ukraine
On December 23, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and TD Bank, N.A. (TD) reached a settlement to resolve TD’s violations of the North Korea Sanctions Regulations and the...more
On November 10, the U.S. Departments of State, Treasury, and Commerce issued an unusual joint advisory (the “advisory”) on the risk of investing and interacting with certain Cambodian individuals and entities. The advisory is...more
12/8/2021
/ Cambodia ,
Corruption ,
Executive Orders ,
High-Risk Countries ,
Office of Foreign Assets Control (OFAC) ,
Risk Factors ,
Sanctions ,
Trade Restrictions ,
U.S. Commerce Department ,
U.S. Treasury ,
US Department of State
• Actions underscore long arm of U.S. sanctions jurisdiction
• Voluntary disclosures and cooperation can lead to significant penalty reductions
• Facilitation of a violation is treated the same as a direct...more
3/5/2020
/ Civil Liability ,
Civil Monetary Penalty ,
Cooperation ,
Economic Sanctions ,
Enforcement Actions ,
General Licenses ,
Global Terrorism Sanctions Regulations (GTSR) ,
Jurisdiction ,
Myanmar ,
Office of Foreign Assets Control (OFAC) ,
Sanction Violations ,
SDN List ,
Shipping ,
Telecommunications ,
Voluntary Disclosure
In case you missed it, we ended 2019 with a webinar on current topics in U.S. economic sanctions. Below are several key points from the webinar:
Types of sanctions vary. Broad country-based sanctions prohibit transactions...more
Report on Supply Chain Compliance 3, no. 2 (January 23, 2020) -
The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC), the primary U.S. government agency that administers U.S. economic sanctions, was busy...more
1/24/2020
/ Aircraft Sales ,
Airlines ,
Apple ,
Aviation Contracts ,
Civil Monetary Penalty ,
Compliance ,
Cross-Border Transactions ,
Economic Sanctions ,
Foreign Narcotics Kingpin Sanctions Regulations (FNKSR) ,
Foreign Suppliers ,
Non-US Entities ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Risk Assessment ,
Risk Mitigation ,
Sanction Violations ,
Screening Procedures ,
SDN List ,
Settlement ,
Slovenia ,
Software ,
Sudan ,
Supply Chain ,
Ukraine ,
Voluntary Disclosure
• $2 million penalty against Exxon overturned
• Court concluded that OFAC failed to provide clear notice of violative conduct
• Companies are at risk when acting in context of ambiguous agency guidance
At the end of...more
1/22/2020
/ Civil Monetary Penalty ,
Corporate Counsel ,
Economic Sanctions ,
Enforcement Guidance ,
Executive Orders ,
Exxon Mobil ,
International Emergency Economic Powers Act (IEEPA) ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Prohibited Transactions ,
Reversal ,
Rosneft ,
Russia ,
Sanction Violations ,
SDN List ,
Ukraine ,
Vacated
The U.S. Treasury Department, Office of Foreign Assets Control (OFAC), the main U.S. government body that administers U.S. economic sanctions and embargoes, continues to be busy. In September 2019 alone, OFAC has announced...more
9/27/2019
/ China ,
Economic Sanctions ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
Iran ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Settlement Agreements ,
Sudan ,
Trade Relations ,
Trump Administration ,
Unfair or Deceptive Trade Practices ,
Venezuela