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The Trump Administration is aggressively pursuing export controls and sanctions enforcement. In two separate cases, the Treasury Department’s Office of Foreign Asset Control and the Commerce Department’s Bureau of Industry...more
The Commerce Department issued new guidance for financial institutions on best practices for compliance with the Export Administration Regulations (EAR). Available here, the guidance emphasizes enhanced due diligence, ongoing...more
October was a robust month for compliance with agency actions and guidance concerning anti-boycott, forced labor, section 301 exclusions, outbound investment, and sanctions. The International Trade Commission also voted...more
On May 10, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an Interim Final Rule (IFR), effective August 8, 2024, that updates the Reporting, Procedures, and Penalties Regulations....more
On 6 March 2024, the US Department of Commerce, Department of the Treasury and Department of Justice issued a Tri-Seal Compliance Note (compliance note) advising foreign-based companies and individuals to assess their...more
New Tri-Seal Compliance Note highlights sanctions and export control compliance expectations for non-U.S. persons. Three agencies overseeing U.S. trade law compliance provided an overview of where U.S. sanctions and export...more
On March 6, 2024, the U.S. Departments of Commerce, Justice, and the Treasury issued a Tri-Seal Compliance Note (Compliance Note) stressing the need for non-U.S. persons to comply with U.S. sanctions and export controls. The...more
On Wednesday, March 6, 2024, the Department of Commerce, Department of the Treasury and Department of Justice issued another Tri-seal Compliance Note, focusing this time on the obligations of foreign based persons complying...more
On July 26, 2023, the U.S. Department of Justice’s (“DOJ”) National Security Division (“NSD”), the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”), and the U.S. Department of the Treasury’s Office of...more
The U.S. Departments of Commerce, Justice and Treasury have issued a “Tri-Seal” Compliance Note regarding national security laws and regulations and the voluntary self-disclosure of potential violations, highlighting...more
United States international trade regulatory agencies have updated voluntary self-disclosure (“VSD”) policies and guidance in an effort to incentivize private sector companies and individuals to self-report violations of U.S....more
In a relatively rare move for four (4) Cabinet-level Departments, the U.S. Departments of Commerce, Justice, State and Treasury issued an advisory notice on June 9, 2023, aimed specifically at reminding industry of their...more
Russia - Russian National Charged with Supplying U.S. Technology to the Russian and North Korean Governments (DOJ Action) Those involved. Ilya Balakaev, Russian national. Charges and penalties. Conspiracy to...more
The Week in Review delivers the impact and analysis for the public, private, and non-profit sectors from our daily reporting of the evolving global sanctions campaign against Russia. This week, we reviewed the recent...more
Following Russia’s recognition of breakaway regions in Ukraine and full-scale invasion of the country, authorities in the United States, United Kingdom, European Union, and across the globe imposed a sweeping array of trade...more
On April 29, 2021, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of Treasury, and the Bureau of Industry and Security (“BIS”) of the U.S. Department of Commerce announced settlements with German...more
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
ANTICORRUPTION DEVELOPMENTS - DOJ Files Superseding Indictment in Haitian Port Corruption Plot - On October 30, 2018, the U.S. Department of Justice (DOJ) filed a superseding indictment in the District of Massachusetts...more