In March 2024, NSD issued an updated Enforcement Policy for Business Organizations (NSD Enforcement Policy) that includes the M&A Policy. Under the M&A Policy, where an acquiring company makes a qualifying voluntary...more
Key Points -
On March 2, 2023, DOJ announced that its NSD would hire more than 25 new prosecutors to investigate and prosecute sanctions evasion, export controls violations and similar economic crimes. Consistent with...more
Introduction -
In 2022, the United States, European Union (EU) and United Kingdom, along with a significant number of other partners and allies, imposed an unprecedented number of economic, financial and trade sanctions...more
Key Points -
The United States, European Union, United Kingdom and other U.S. allies are currently considering a range of severe economic measures against Russia to impose in the event of a Russian military incursion into...more
1/31/2022
/ Export Administration Regulations (EAR) ,
Export Controls ,
Financial Institutions ,
Foreign Policy ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Pipelines ,
Russia ,
Sanctions ,
SDN List ,
Ukraine
On October 18, 2021, the U.S. Treasury Department released a long awaited report on its first of its kind “top to bottom” review of U.S. economic and financial sanctions. The report does not make or recommend any immediate or...more
Key Points
- On February 11, 2021, in the first deployment of sanctions since assuming office, President Biden issued EO 14014, authorizing sanctions against members of the Burmese military and related parties responsible...more
- On February 18, 2020, OFAC designated Rosneft Trading, S.A. (Rosneft Trading), a subsidiary of Russia-based Open Joint-Stock Company Rosneft Oil Company (Rosneft Oil Company), and its president, Didier Casimiro, on the SDN...more
2/21/2020
/ Blocked Person ,
Crude Oil ,
Economic Sanctions ,
Energy Sector ,
Export Controls ,
Exports ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
SDN List ,
Venezuela
• On December 13, 2019, the Department of Justice (DOJ) revised and re-issued its “Export Controls and Sanctions Policy for Business Organizations” (the “Revised Policy”) to “provide greater clarity for companies faced with a...more
12/20/2019
/ Corporate Counsel ,
Corporate Misconduct ,
Criminal Penalties ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Export Controls ,
Exports ,
Financial Institutions ,
Incentives ,
Non-Prosecution Agreements ,
Office of Foreign Assets Control (OFAC) ,
Sanction Violations ,
Voluntary Disclosure
• On August 8, OFAC issued Findings of Violation to two U.S. companies in relation to administrative subpoenas with follow-up responses deemed by OFAC to be inaccurate or incomplete.
• These recent actions build upon a...more
On August 4, 2017, the Council of the European Union (the “Council”) made six new designations to the list of persons subject to restrictive measures in respect of actions undermining or threatening the territorial integrity,...more
8/21/2017
/ Annexation ,
Asset Freeze ,
Crimea ,
Economic Sanctions ,
Energy Sector ,
EU ,
Export Controls ,
Oil & Gas ,
Power Plants ,
Russia ,
Siemens ,
Trade Restrictions ,
Travel Ban ,
Ukraine
Key Points -
- This action marks the first time sanctions have been imposed under the Cybersecurity Sanctions Program established on April 1, 2015, with the designation of nine entities and individuals.
-...more
1/5/2017
/ Barack Obama ,
Bureau of Industry and Security (BIS) ,
Cybersecurity ,
Department of Homeland Security (DHS) ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
FBI ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanctions ,
SDN List ,
U.S. Commerce Department
On October 2, 2016, the National Security Division (NSD) of the U.S. Department of Justice (DOJ) established a formal, voluntary self-disclosure program for criminal violations of U.S. economic sanctions and export controls...more
On July 29, 2016, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) issued a new General License J (GL-J). GL-J authorizes the reexportation of certain civil aircraft on temporary sojourn to Iran,...more
On June 3, 2016, the U.S. Department of State, Directorate of Defense Trade Controls (DDTC) and the Department of Commerce, Bureau of Industry and Security (BIS) issued changes to the International Traffic in Arms Regulations...more
On March 24, 2016, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued General License I authorizing U.S. persons to undertake certain transactions ordinarily incident to the negotiation of, and...more
In an extraordinary development, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a new rule, effective March 24, 2016, creating a temporary general license for two entities—Zhongxing...more
On Wednesday, March 16, 2016, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) implemented amendments to the Cuban...more
Effective March 8, 2016, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a final rule adding Zhongxing Telecommunications Equipment Corporation (ZTE) of Shenzhen, China, and the following...more
If you read one thing…
- Further relaxation of sanctions on Cuba, effective on January 27, 2016, allows U.S. financial institutions to finance authorized exports and reexports to Cuba of items other than...more
On January 16, 2016, the International Atomic Energy Agency (IAEA) verified, and U.S. Secretary of State John Kerry confirmed, that Iran had implemented its key nuclear-related measures described in the Joint Comprehensive...more
On November 2, 2015, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) updated the List of Medical Supplies eligible for export or reexport to Iran under the general license set forth at Section...more
On October 18, 2015, the day on which the Joint Comprehensive Plan of Action (“JCPOA”) became effective (“Adoption Day”), the U.S. Department of State (“State Department”) issued contingent waivers of certain extraterritorial...more
10/21/2015
/ Banking Sector ,
Energy Sector ,
Export Controls ,
Exports ,
IAEA ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
US Department of State ,
Waivers
On September 2, 2015, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a final rule amending the Export Administration Regulations (EAR) by adding 29 parties to its Entity List, a...more
9/9/2015
/ Bureau of Industry and Security (BIS) ,
Defense Sector ,
Energy Sector ,
EU ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Russia ,
Sanctions ,
SDN List ,
U.S. Commerce Department
On August 7, 2015, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published a final rule adding the Yuzhno-Kirinskoye Field, a Russian oil and gas field located in the Sea of Okhotsk, to its Entity...more
On June 8, attorneys for the U.S. Department of Justice (DOJ) joined Dutch aerospace company Fokker Services BV (“Fokker”) in appealing the district court’s rejection of Fokker’s deferred prosecution agreement (DPA) with the...more
6/12/2015
/ Aerospace ,
Aircraft Equipment ,
Appeals ,
Burma ,
Civil Monetary Penalty ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Export Controls ,
Exports ,
Fokker ,
Judicial Authority ,
Sanctions ,
Sudan