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
4/8/2022
/ Airlines ,
Biden Administration ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Executive Orders ,
Export Controls ,
Export Terminals ,
Financial Institutions ,
Financial Transactions ,
Russia ,
Travel Restrictions ,
U.S. Commerce Department
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 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 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
On March 18, citing publicly available information, the Bureau of Industry and Security (BIS) issued a notice (the Notice) identifying 100 commercial and private aircraft that have flown into Russia in apparent violation 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 September 28, the U.S. Commerce Department, Bureau of Industry and Security (BIS) announced that it has imposed a civil penalty fine and denial of export privileges against Vorago Technologies (Vorago) for the unauthorized...more
On August 3, 2021, the U.S. State Department Directorate of Defense Trade Controls (DDTC) issued an order laying out charges and imposing a monetary penalty of $6.6 million on Keysight Technologies, a U.S. technology and...more
8/20/2021
/ China ,
Commodities ,
Consent Agreements ,
Directorate of Defense Trade Controls (DDTC) ,
Enforcement ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
ITAR ,
Penalties ,
Russia ,
Software ,
Technology
• $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
• Russian corporations de-listed through significant specific steps agreed to with OFAC
• Exporter settles for $7.7 million and agrees to comprehensive compliance measures
• OFAC outlines sanctions compliance best...more
1/4/2019
/ Audits ,
Best Practices ,
Certifications ,
Delisting ,
Economic Sanctions ,
Enforcement Actions ,
Exports ,
Fifty Percent Rule ,
Foreign Corrupt Practices Act (FCPA) ,
Internal Controls ,
Office of Foreign Assets Control (OFAC) ,
Risk Assessment ,
Russia ,
SDN List ,
Settlement Agreements
• Penalties imposed for violations of U.S. sanctions on Russia and Ukraine
• Violations identified during pre-acquisition due diligence on contractor
• Denied persons screening was conducted but missed prohibited...more
12/13/2018
/ Blocked Entities ,
Due Diligence ,
Economic Sanctions ,
Exporters ,
Federal Contractors ,
Foreign Acquisitions ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Policies and Procedures ,
Risk Assessment ,
Russia ,
Sanction Violations ,
Screening Procedures ,
SDN List ,
Ukraine ,
Voluntary Disclosure
• Economic sanctions and export restrictions extended
• Russian investment in United States likely subject to heightened scrutiny
• Diligence on Russia transactions and business partners is essential to ensure...more
9/27/2018
/ CAATSA ,
CBW Act ,
CFIUS ,
Defense Sector ,
Economic Sanctions ,
Executive Orders ,
Export Controls ,
Exports ,
FIRRMA ,
Foreign Investment ,
Foreign Policy ,
General Licenses ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Trade Restrictions ,
Trump Administration ,
U.S. Treasury
Over the past month, we have closely monitored efforts by the U.S. Congress to tie the president’s hands over sanctions on Russia. Today, the president signed the Countering America’s Adversaries Through Sanctions Act...more