Between tariffs, tightening export controls, evolving sanctions, and ramped up enforcement, the cost and complexity of compliance is rising for oil and gas supply chains. ACI’s Trade & Sanctions Compliance for the Oil and...more
This is the fifth post in this year’s series examining important trends in white collar law and investigations. Our previous post discussed trends in State AG enforcement. Up next: SEC Enforcement in 2022: A Look Ahead. ...more
The U.S. Government is continuing its frequent and highly visible use of denied party lists as an important tool in administering the export control laws. Each of the Bureau of Industry and Security (BIS), the Office of...more
There’s been a non-stop bombardment of recent export amendments involving China and other “countries of concern” within the last six months. The main driver behind these has been the U.S. Government’s concern about the...more
Rounding out an already-intense 2020, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued three notices in December that expanded export sanctions and restrictions against Chinese, Russian, and...more
Turning to the business of exports from the United States, the next section is a must-read for any company doing business in the United States or from the United States. Or for that matter, any company competing with affected...more
Over the course of this year, the U.S. government has enacted a number of new regulatory changes, including changes aimed at addressing national security concerns related to countries of interest, including China, Russia, and...more
On April 28, 2020, the US Commerce Department's Bureau of Industry and Security (BIS) published two new final rules amending the Export Administration Regulations (EAR). One of the final rules removes license exception Civil...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 Extends FCPA Corporate Enforcement Policy to Misconduct in Mergers and Acquisitions - On July 25, 2018, in a speech to the Ninth Global Forum on Anti-Corruption Compliance in High Risk...more
Recently, many revisions to U.S. sanction programs (both implemented and under consideration) have been the topic of much public discussion. Often, the legal status or these revisions may be difficult to determine....more
ANTICORRUPTION DEVELOPMENTS – Global Compliance Overhaul for SAP as DOJ and SEC Investigate Payments Allegedly Related to South African Government Contracts – On October 26, 2017, German software company SAP SE...more