On July 29, 2024, the U.S. Department of State’s Directorate of Defense Trade Controls (DDTC) issued a proposed rule to revise the definition of “defense service” and the scope of related controls under existing International...more
The U.S. Department of Commerce’s Bureau of Industry and Security has published a compliance note on voluntary self-disclosure trends and a compendium of export compliance resources targeted to the academic community. The...more
The U.S. Department of Commerce’s Bureau of Industry and Security released an interim final rule (IFR) on July 18th amending the Export Administration Regulations (EAR). This amendment revises the scope of “standards-related...more
The US Department of the Treasury’s Office of Foreign Assets Control has released guidance following on Congress’ extension of the statute of limitations for violations of certain sanctions and related recordkeeping...more
The Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury has issued guidance on best practices for submitting information and documents in response to OFAC administrative subpoenas, requests for...more
The Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued an interim final rule set to take effect August 8, 2024, which amends the Reporting, Procedures, and Penalties Regulations (the “Regulations”)...more
On May 15, 2024, the U.S. Commerce Department’s Bureau of Industry and Security issued an antiboycott compliance advisory regarding the Turkish government’s announcement that it will suspend all imports and exports to and...more
Congress has doubled the statute of limitations for violations of most U.S. sanctions programs administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control. Companies should be aware of the...more
Businesses working with U.S. export-controlled technology are subject to U.S. export control laws which impose restrictions on the release of such technology to certain foreign persons—even within U.S. borders. A company that...more
On April 10, 2024, the U.S. Department of State’s Directorate of Defense Trade Controls (“DDTC”) published guidance for universities and research centers to comply with International Traffic in Arms Regulations (“ITAR”). DDTC...more
On 28 March, the U.S. Commerce Department, Bureau of Industry and Security (BIS) published a list of entities that have been identified as having made a boycott-related request in order to help U.S. companies, including...more
October 2023 marked the first anniversary of the enhanced partnership between the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the United Kingdom Office of Financial Sanctions...more
The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) has further updated its voluntary self-disclosure (VSD) process by establishing streamlined procedures for minor or technical violations of the Export...more
On December 22, 2023, President Biden issued a new Russia-related Executive Order (“EO”) targeting foreign financial institutions (“FFIs”) that support Russia’s military-industrial base. The new EO allows the U.S. government...more
On December 12, the Select Committee on the Chinese Communist Party of the U.S. House of Representatives issued a comprehensive economic strategy containing over 160 policy recommendations intended to “to fundamentally reset...more
The U.S. Congress enacted the Corporate Transparency Act (CTA) in 2020. The CTA for the first time created a federal obligation to report beneficial ownership information for most U.S. entities (and foreign entities doing...more
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
Deputy Attorney General Lisa Monaco announces a new safe harbor policy for voluntary self-disclosures of acquired entities’ criminal misconduct. Although the new safe harbor provides clear timelines for disclosure, the costs...more
The US Treasury’s Financial Crimes Enforcement Network (FinCEN) has issued a Small Entity Compliance Guide to aid in understanding and complying with the Corporate Transparency Act’s beneficial ownership information reporting...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
8/2/2023
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Department of Justice (DOJ) ,
Export Administration Regulations (EAR) ,
Export Controls ,
FinCEN ,
Office of Foreign Assets Control (OFAC) ,
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Self-Disclosure Requirements ,
U.S. Commerce Department ,
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Voluntary Disclosure
The US Bureau of Industry and Security has announced that the “Five Eyes” countries have committed to formally coordinate on export controls enforcement. The intelligence alliance member countries hope to increase enforcement...more
The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) clarified its policy regarding voluntary self-disclosures and enforcement actions on April 18, 2023. Historically, a failure to voluntarily...more
On Tuesday April 18, 2023, the U.S. Department of Justice (DOJ) Civil Rights Division’s Immigrant and Employee Rights Section (IER) issued additional guidance regarding compliance with U.S. anti-discrimination laws at the...more
In 2021, the Export Controls and Human Rights Initiative (“ECHRI”) was launched at the first Summit for Democracy as part of the Presidential Initiative for Democratic Renewal. This year, during the Summit for Democracy 2023...more
On 7 March 2023, U.S. Senators Mark Warner and John Thune introduced the Restricting the Emergence of Security Threats that Risk Information and Communications Technology (RESTRICT) Act, sweeping legislation aimed at...more