News & Analysis as of

Export Controls FinCEN

Cooley LLP

US, UK and EU Begin Easing Sanctions on Syria Amid Political Transition

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Following an announcement by President Donald Trump on May 13, 2025, that he would order the cessation of US sanctions against Syria, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General...more

Foley Hoag LLP

U.S. and EU Take Steps Towards Easing Sanctions on Syria

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On May 23, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License No. 25 (“GL 25”) authorizing certain transactions involving Syria and a specified list of blocked...more

BakerHostetler

Syria Sanctions Eased: What is the Impact on Your Business?

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On May 23, 2025, the United States formally eased its economic sanctions on Syria. This action authorizes a significant number of transactions that previously would have violated U.S. sanctions. ...more

K2 Integrity

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

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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

American Conference Institute (ACI)

FCPA, Export Controls, and Sanctions Enforcement: Adjusting Compliance Strategies for the New Normal

As the interplay between export controls, trade sanctions, and anticorruption enforcement continues to intensify, multinational companies must remain vigilant in ensuring that their compliance programs address the many...more

White & Case LLP

The Shadow Financial System

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The concept of the shadow financial system rose to international prominence in the aftermath of the 9/11 terrorist attacks. In an interview with a Pakistani newspaper a month later, Osama bin Laden stated that Al Qaeda were...more

The Volkov Law Group

Congress Extends Sanctions Statute of Limitations And Addresses Other National Security Issues

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On April 24, 2024, President Biden signed into law a sweeping national security legislative package that included the 21st Century Peace Through Strength Act, which includes measures to promote sanctions and export controls...more

The Volkov Law Group

DOJ and OFAC Sanctions and Export Control Detection Strategies

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In this new aggressive era of sanctions and export controls enforcement, companies need to understand the potential risks that DOJ and/or OFAC may identify a company for sanctions investigation....more

WilmerHale

Hiding in Plain Sight: New Ukraine and Israel Aid Package Includes Significant Changes to US Sanctions and Export Control Laws

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On April 24, 2024, President Biden signed into law H.R. 815, an emergency appropriations package billed as authorizing $95 billion in foreign aid to Ukraine and Israel (the Act). While the Ukraine and Israel aid provisions...more

Holland & Knight LLP

New Tri-Seal Compliance Note Issued to Non-U.S. Persons

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The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC), U.S. Department of Commerce's Bureau of Industry and Security (BIS) and U.S. Department of Justice (DOJ) on March 6, 2024, issued a Tri-Seal...more

K2 Integrity

FINCast Ep. 39 – State of Russia Sanctions Two Years After the Invasion

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On FINCast Episode 39, Juan Zarate sits down with K2 Integrity’s Katya Hazard and Amir Fadavi to discuss the state of Russia-related sanctions and to explore what has worked and what may require further coordinated efforts to...more

Seward & Kissel LLP

The Importance of Sanctions and Export Control Compliance

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The United States manages more than three dozen separate economic and trade sanctions programs. Those programs target specified foreign governments along with thousands of named individuals, groups and entities in accordance...more

Bracewell LLP

“Export Controls Are the New Sanctions” and Other Enforcement Trends for 2024

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2023 was a banner year in the sanctions space and regulators seem primed to continue that performance in 2024. In December 2023, numerous government officials and industry experts convened at the New York Forum on Economic...more

Akin Gump Strauss Hauer & Feld LLP

7 Enforcement Predictions For US Export Controls, Sanctions

Within the trade bar there is cautiousness, curiosity and skepticism at the numerous pronouncements signaling greater enforcement of export controls and sanctions by the Bureau of Industry and Security, the Office of Foreign...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – November 2023 Update

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You are reading the November 2023 Update of the Bass, Berry & Sims Enforcement Roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox. ...more

Foodman CPAs & Advisors

Control De Exportaciones: Señales De Alerta De FinCEN

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El 6/11/23, la Oficina de Industria y Seguridad (“BIS” o “Bureau of Industry and Security”) del Departamento de Comercio y FinCEN emitieron un Aviso Conjunto sobre la evasión del control de exportaciones destacando un nuevo...more

Foodman CPAs & Advisors

Export Control FinCEN Red Flags

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On 11/6/23, the Department of Commerce’s Bureau of Industry and Security (BIS) and FinCEN issued a joint notice regarding export control evasion highlighting a new Suspicious Activity Report key term (“FIN-2023-GLOBALEXPORT”)...more

Hogan Lovells

U.S. regulators issue joint notice concerning SAR key term and global evasion of trade controls

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On 6 November 2023, the Department of the Treasury’s Financial Crimes Enforcement Network and the Department of Commerce’s Bureau of Industry and Security issued a joint notice concerning a new Suspicious Activity Report key...more

The Volkov Law Group

BIS and FinCEN Release Joint Notice Concerning Global Export Control Evasion

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On November 6, 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) and the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) released a new joint notice concerning...more

American Conference Institute (ACI)

Navigating U.S. Sanctions and Export Control Restrictions

Over the last several months, companies have become entangled in an increasingly complex web of new and expanded sanctions and export control restrictions related to Russia in response to its war on Ukraine. The current...more

Ballard Spahr LLP

FinCEN and BIS Issue Joint Notice on SAR Filings for Evasion of U.S. Export Controls

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The Financial Crimes Enforcement Network (“FinCEN”) and the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) recently issued Joint Notice FIN-2023-NTC2, “Announnc[ing] New Reporting Key Term and...more

Foodman CPAs & Advisors

Nota De Cumplimiento Del BIS, DOJ Y OFAC

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El 26/07/2023, el Departamento de Justicia de los EE. UU. (DOJ), la Oficina de Industria y Seguridad del Departamento de Comercio de los EE. UU. (BIS) y la Oficina de Control de Activos Extranjeros (OFAC) del Departamento del...more

Foodman CPAs & Advisors

Compliance Note From BIS, DOJ & OFAC

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On 07/26/2023, the U.S. Department of Justice (DOJ), the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), issued a...more

Fenwick & West LLP

U.S. Government Intensifies Focus on Russian Sanctions Evasion

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The U.S. government is turning up the dial on its efforts to combat evasion of export controls and sanctions against Russia. The severe trade restrictions against Russia (and Belarus) have seen continuous escalation since...more

Ballard Spahr LLP

FinCEN Analysis Reveals Patterns and Trends in Suspected Evasion of Russia-Related Export Controls

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Following Russia’s invasion of Ukraine, the Financial Crimes Enforcement Network (“FinCEN”) and the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a joint alert and a supplemental alert (the...more

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