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National Security Economic Sanctions Corporate Counsel

Wiley Rein LLP

Update: Enforcement of DOJ Data Security Program Set to Begin July 9

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The U.S. Department of Justice (DOJ) is set to enforce its sweeping new rule on certain U.S. data transactions with countries of concern and covered persons as of July 9, 2025. The new rule regarding “Preventing Access to...more

Morrison & Foerster LLP

DOJ Issues First-Ever Declination Under Corporate Disclosure M&A Policy

On June 16, 2025, the Department of Justice (DOJ) National Security Division (NSD) announced that it declined to charge private equity firm White Deer Management LLC (“White Deer”) and its affiliates after the company...more

Skadden, Arps, Slate, Meagher & Flom LLP

OFSI Issues First-Ever Monetary Penalty for a Failure To Provide Information: Key Considerations for Companies

The Offence and Penalty - On 8 May 2025, the UK’s Office of Financial Sanctions Implementation (OFSI) published its 11 April 2025 notice of its first-ever monetary penalty for an information offence relating to financial...more

Troutman Pepper Locke

Trump Administration’s First Export Control Action – Reading the Tea Leaves

Troutman Pepper Locke on

On March 25, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced a significant expansion of its Entity List restrictions, adding 80 entities from China, the United Arab Emirates, South Africa,...more

Skadden, Arps, Slate, Meagher & Flom LLP

The Sanctions Puzzle: Key Areas To Watch in 2025 and Beyond

The past weeks and months have brought about tremendous political change in the West, as we move toward a new U.S. administration, a new College of Commissioners in Brussels and a new Polish presidency of the Council of the...more

Skadden, Arps, Slate, Meagher & Flom LLP

OFSI Issues First Monetary Penalty for Breach of Sanctions Imposed on Russia in Response to Its Invasion of Ukraine

On 27 September 2024, the UK’s financial sanctions regulator, the Office of Financial Sanctions Implementation (OFSI), announced that it had issued its first monetary penalty for a breach of UK financial sanctions imposed...more

Morrison & Foerster LLP

War Aid and Sanctions: National Security Act Includes Significant New Sanctions Authorities

On April 24, 2024, President Biden signed into law a long-debated $98 billion foreign aid and national security legislative package (the “Act”) providing funds for Israel, Taiwan, and Ukraine, and authorizing new sanctions...more

Morrison & Foerster LLP

OFAC Year in Review 2023 – Part 1

2023 was another record year for U.S. sanctions and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). Most prominently, OFAC continued to impose significant additional sanctions on Russia in...more

Morgan Lewis

Update: Russian Draft Law to Criminally Prosecute Directors and Officers for Sanction Compliance

Morgan Lewis on

A draft law submitted for consideration to the State Duma—the lower chamber of the Russian parliament—would amend the Russian Criminal Code to make compliance with sanctions a criminal offense for directors and officers,...more

WilmerHale

Treasury Releases Long-Awaited Sanctions Policy Review

WilmerHale on

The US Treasury Department has released its 2021 Sanctions Review (the “Review”), which describes the US sanctions framework and the agency’s future sanctions priorities. The Review reflects on the evolution over two decades...more

The Volkov Law Group

SAP Reaches Broad Settlement and Agrees to Pay More Than $8 Million for Violations of Iran Sanctions Program (Part I of IV)

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In a precedent-setting agreement, the Justice Department, OFAC and the Bureau of Industry and Security announced a settlement with SAP SE for more than $8 million for numerous violations of the Iran Sanctions program....more

Akin Gump Strauss Hauer & Feld LLP

Reminder Regarding the Jurisdictional Reach and Limits of U.S. Export Control, Sanctions, and Foreign Investment Regulations

United States export control, sanctions, and foreign investment (CFIUS) regulations advance U.S. national security and foreign policy interests, but in very different ways. They are also quite complex. As a result, media...more

Foley Hoag LLP - White Collar Law &...

White Collar Year in Preview: Sanctions/Export Controls Trends in 2020

This is the sixth in our start-of-year series examining important trends in white collar law and investigations in the coming year. Our previous entry discussed enforcement by the Massachusetts Attorney General’s Office in...more

Faegre Drinker Biddle & Reath LLP

U.S. State Department Changes Export Control Requirements for Secure Handling of Defense Technical Data, Easing Burden on U.S....

On December 26, 2019, the U.S. State Department’s Directorate of Defense Trade Controls (DDTC) announced it is amending the International Traffic in Arms Regulations (ITAR) to exclude certain secure transfers of defense...more

Faegre Drinker Biddle & Reath LLP

Important New Guidance for Companies Considering Voluntary Disclosures of Export Control and Sanctions Violations

On December 13, 2019, the U.S. Department of Justice’s National Security Division (NSD) issued important new policy guidance regarding voluntary disclosures of export control and sanctions laws violations. Among other things,...more

Morrison & Foerster LLP

New EU Investment Screening Rules: 10 Key Things Dealmakers Need to Know

The EU has recently laid the ground to take a more active role in the screening of foreign direct investment (FDI). On April 10, 2019, the EU formally established a framework for foreign investment screening including a...more

Perkins Coie

OFAC Issues Sanctions Compliance Program Guidance

Perkins Coie on

The Office of Foreign Assets Control (OFAC), an agency of the U.S. Department of the Treasury, administers and enforces U.S. economic sanctions programs against targeted foreign governments, individuals, groups and entities...more

Morrison & Foerster LLP

Sanctions Enforcement Tips from Former OFACers

Morrison & Foerster’s National Security practice provides strategic advice and counseling to clients on a broad range of challenging regulatory and compliance matters in the national security space. In advising clients, the...more

Morrison & Foerster LLP

DOJ Signals Once More that FARA Is an Enforcement Priority

In another indication of the U.S. Department of Justice’s increased focus on the Foreign Agents Registration Act (FARA), Assistant Attorney General John Demers announced that the Department is overhauling its FARA enforcement...more

Morrison & Foerster LLP

OFAC Has Been Talking About Compliance Through Enforcement - Have You Been Listening?

Last Thursday, January 31, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued its first enforcement action of 2019, a fascinating case involving false eyelashes that teaches that virtually any...more

Skadden, Arps, Slate, Meagher & Flom LLP

"US Announces Record-Setting Penalties for Violations of Export Controls and Economic Sanctions"

On March 7, 2017, the United States announced that China’s Zhongxing Telecommunications Equipment Corporation and ZTE Kangxun Telecommunications Ltd. and their respective affiliates (collectively, ZTE) had agreed to a record...more

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