News & Analysis as of

Russia National Security Corporate Counsel

Morrison & Foerster LLP

FTC Looks to Leverage PADFAA Enforcement to Help Limit Exposure of Consumer Data

In recent comments, Commissioner Holyoak signaled that the Federal Trade Commission will prioritize enforcement of the Protecting Americans’ Data from Foreign Adversaries Act (PADFAA), a law that empowers the FTC to police...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

Sheppard Mullin Richter & Hampton LLP

A Roadmap for Export Controls? Project 2025 and the Future of U.S. Exports – Part I

The second Trump administration has come flying out of the starting blocks on international trade policy actions—imposing and rescinding, shaping and reshaping tariffs, sanctions, and export controls. The executive orders and...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

New DHS Security Requirements Impact Compliance for Employers with Workers in Six “Countries of Concern”

The U.S. Department of Homeland Security (DHS) recently published new security requirements for certain restricted transactions covered by the U.S. Department of Justice’s (DOJ) sensitive data export rules. ...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

Commerce Issues First-Ever ICTS “Final Determination” Banning Kaspersky Cybersecurity Products

On June 24, 2024, the Commerce Department published a Final Determination under its Information and Communications Technology and Services (ICTS) authorities. The determination prohibits the Russian-controlled cybersecurity...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

Wilson Sonsini Goodrich & Rosati

Compliance Reminder: SEC Disclosure Considerations Arising from Russia's Invasion of Ukraine

Many public companies are beginning preparations for filing quarterly reports on Form 10-Q for the second quarter of calendar 2022. As they do so, they should review and consider the U.S. Securities and Exchange Commission...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

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

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