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Warner Norcross + Judd

Avoid the October Surprise: What You Need to Know About DOJ’s New Data Security Program

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The Department of Justice’s (“DOJ”) Data Security Program (“the Program”, 28 C.F.R. Part 202) went into effect on April 8 with a 90-day period of limited enforcement. With DOJ now expecting full compliance, with additional...more

Morrison & Foerster LLP

U.S. Sanctions Enforcement: 2024 Lessons Learned and 2025 Expectations

As the third month of the second Trump administration comes to a close, the lack of any public enforcement action by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has sanctions watchers...more

Conyers

International Sanctions Requirements for Virtual Asset Service Providers: a Cayman Perspective

Conyers on

As the war continues to rage on the Eastern front between Russia and Ukraine, the financial sanctions resulting from the initial invasions and ongoing conflict seem likely to continue to play a significant part in the global...more

K2 Integrity

First Ever Targeted Guidance On Financial Institutions’ Compliance With Export Administration Regulations

K2 Integrity on

On 9 October 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published its first ever unilateral guidance specifically addressed to financial institutions (FIs). The Guidance to Financial...more

WilmerHale

BIS Sets Higher KYC Standards for Companies and Universities Over Russia Diversion Concerns

WilmerHale on

On July 10, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) released new guidance (the “July 10 Release”) outlining different types of precautionary letters (“supplier list” letters, “Project...more

Pillsbury Winthrop Shaw Pittman LLP

FinCEN’s Proposed Rule to Regulate Investment Advisers: The Questions Industry Should Be Following

FinCEN is focused on customer due diligence, and both the 2024 Investment Adviser Risk Assessment and proposed rule indicate that investment advisers will be expected to assess customer identity, business model, and sources...more

K2 Integrity

Sanctions Against Russia: U.S. Introduces New Russia-Related Sanctions Targeting Foreign Financial Institutions And Tightens Other...

K2 Integrity on

On 22 December 2023, the Biden administration issued Executive Order 14114, “Taking Additional Steps with Respect to the Russian Federation’s Harmful Activities” (EO 14114), thereby amending EOs 14024 and 14068. The new EO...more

Holland & Knight LLP

2023 NDAA Tightens Controls on Chinese Semiconductors in Government Contractor Supply Chains

Holland & Knight LLP on

President Joe Biden signed into law the James M. Inhofe National Defense Authorization Act for Fiscal Year 2023 (2023 NDAA or Defense Bill) on Dec. 23, 2022. The Defense Bill, which passed the U.S. House of Representatives on...more

Holland & Knight LLP

A Guide for Early-Stage Companies on Trade Compliance and Foreign Investment

Holland & Knight LLP on

Are you looking to hire a star engineer who is a foreign national? Are you considering raising capital from a foreign venture capital firm or other foreign investor? Are you interested in sourcing components or creating...more

Morrison & Foerster LLP

UK Authorities Issue Red Alert on Russia Sanctions Evasion Typologies

On 13 July 2022, the National Economic Crime Centre, a multi-agency unit in the National Crime Agency (NCA), and the Office of Financial Sanctions Implementation, working in conjunction with law enforcement and financial...more

K2 Integrity

Sanctions Against Russia: Understanding the Evolving Picture and How to Respond

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...Since the start of the invasion of Ukraine by Russian forces on February 24, the United States (U.S.), United Kingdom (UK), and the European Union (EU) have led a global sanctions campaign against Russia that has been...more

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