Curtis Dombek

Curtis Dombek

Sheppard Mullin Richter & Hampton LLP

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The Baby and the Bathwater: The Department of Commerce’s Bureau of Industry and Security (BIS) Intrusion and Surveillance Software...

If you are not aware, please take note that the July 20, 2015 deadline is fast approaching for comments to the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) proposed rule on the export control of certain...more

7/21/2015 - BIS EAR Export Administration Regulations Export Controls Exports Licensing Rules Software Surveillance U.S. Commerce Department

Implementation Day: Do the Rules Let You Play in the New Ballgame for Business in Iran?

After a twelve-year standoff that saw the United States and Europe ratchet up sanctions pressure on Iran, a diplomatic breakthrough has been reached. But robust trade between Iran and the West will not arise immediately,...more

7/19/2015 - EU Exports IFCA Iran Iran Sanctions Iran Threat Reduction and Syria Human Rights Act Joint Comprehensive Plan of Action (JCPOA) Manufacturers NDAA Non-US Entities Nuclear Power Nuclear Weapons

New EU Rules on Disclosure of Ultimate Beneficial Owners

On June 5, new EU’s anti-money laundering (AML) rules, namely the Fourth EU Anti-Money Laundering Directive (“4AMLD”) and a new Regulation on the information accompanying transfer of funds were published in the Official...more

6/16/2015 - Anti-Money Laundering Disclosure Requirements Due Diligence EU New Regulations Terrorist Financing Regulations Trusts

U.S. Authorizes Targeted Sanctions Against Overseas Cyber Threats

Cyber threats are one of the U.S.’s top security threats. In just the past year, there has been a significant increase in the frequency, scale and sophistication of cyber intrusions and attacks – many of them originating...more

4/6/2015 - Barack Obama Critical Infrastructure Sectors Cyber Threats Cybersecurity Executive Orders National Security Sanctions

Add Importers to Those Facing Expanding Whistleblower Claims under the False Claims Act

On February 12, 2015, the Department of Justice (DOJ) announced that three U.S.-based importers had agreed to pay more than $3 million to resolve a lawsuit brought by the United States under the False Claims Act (FCA)...more

3/6/2015 - Antidumping Duties Countervailing Duties Customs and Border Protection DOJ Enforcement Actions False Claims Act False Statements Importers Whistleblowers

OFAC Issues Cuban Asset Control Regulations Focused on the U.S. Financial Sector

On January 15, 2015, the Department of Treasury’s Office of Foreign Assets Control (OFAC) amended the Cuban Assets Control Regulations to implement changes in U.S. policy toward Cuba announced by President Obama on December...more

1/23/2015 - Amended Legislation Banking Sector Barack Obama CACR Cuba Embargo Executive Orders Export Controls Exports Imports OFAC Sanctions Telecommunications Travel Permits U.S. Commerce Department U.S. Treasury

OFAC Issues Cuban Asset Control Regulations focused on the U.S. Financial Sector

Today, the Department of Treasury’s Office of Foreign Assets Control (OFAC) amended the Cuban Assets Control Regulations to implement changes in U.S. policy toward Cuba announced by President Obama on December 17, 2014....more

1/16/2015 - Amended Regulation Banking Sector Cuba OFAC Sanctions Trade Relations

Mandatory Reporting of Foreign Direct Investments in the U.S.

The Department of Commerce’s Bureau of Economic Analysis (BEA) has reinstated the mandatory reporting requirements of the BE–13, Survey of New Foreign Direct Investment in the United States, which was discontinued in 2009 due...more

12/22/2014 - Foreign Direct Investment Reporting Requirements U.S. Commerce Department

EU Strengthens Economic Sanctions Against Russia

The European Union (EU) put into effect on Friday (September 12, 2014) a new round of economic sanctions against Russia over its role in Ukraine. ...more

9/19/2014 - Asset Freeze EU Russia Sanctions SDN List SSI List Travel Ban Ukraine

Appellate Court Issues Opinion on SEC’s Conflict Minerals Rule

On April 15, the Court of Appeals for the D.C. Circuit issued its opinion in the challenge to the SEC’s Conflict Minerals Rule. We have reviewed the D.C. Court of Appeals decision and find that it leaves much of the SEC’s...more

4/17/2014 - Conflict Mineral Rules Disclosure Requirements First Amendment SEC

Free(er?) Trade - US, EU and Canada Quibble Over Market Access and Domestic Preferences

The US is generally pretty keen on international free trade agreements. And why shouldn’t it be? After all, free trade agreements have the ability to open up foreign markets to US goods and services, allowing new and...more

8/15/2013 - Canada EU Foreign Markets Free Trade Agreement GATT Market Access Rule Tariffs TTIP WTO

Compliance Issues with the New SEC Reporting and Disclosure Requirements Under the Iran Threat Reduction and Syria Human Rights...

Originally published in Securities Regulation & Law Report on December 12, 2012. In August 2012, the Iran Threat Reduction and Syria Human Rights Act of 2012 (‘‘ITRSHRA’’) was passed to expand U.S. sanctions against Iran...more

1/15/2013 - Disclosure Requirements Iran Sanctions Iran Threat Reduction and Syria Human Rights Act Oil & Gas Petroleum SEC

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