We wanted to share an update on Russia sanctions developments in the United States, United Kingdom, and European Union that occurred between March 24 and April 8, 2022. Following new reports of atrocities committed by the...more
We wanted to share an update on Russia sanctions developments in the United Kingdom, European Union, and the United States that occurred between March 16 and 24. As summarized below, key global jurisdictions have continued to...more
Western sanctions against Russia have continued to broaden substantially into new areas of trade, especially in the energy sector. Policymakers in Washington DC, Brussels, London and other allied capitals also continue to...more
3/18/2022
/ Asset Freeze ,
Belarus ,
Blocked Entities ,
Blocked Person ,
Cryptocurrency ,
Economic Sanctions ,
EU ,
Export Controls ,
General Licenses ,
Imports ,
Most-Favored Nations ,
Russia ,
Trade Relations ,
Trade Restrictions ,
UK ,
Ukraine
The United States, the European Union (EU), the United Kingdom (UK), and other allies and partners are implementing wide-ranging, novel sanctions and sweeping export controls against Russia in response to its invasion of...more
2/28/2022
/ Biden Administration ,
Blocked Entities ,
Blocked Person ,
Economic Sanctions ,
Embargo ,
EU ,
Financial Institutions ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
UK ,
Ukraine
Top EU Court Rules on the EU Blocking Regulation Against US Sanctions for the First Time -
On December 21, 2021, the Court of Justice of the European Union (CJEU), sitting as a “Grand Chamber” (a formation used, among...more
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
10/20/2021
/ China ,
Corporate Counsel ,
Economic Sanctions ,
EU ,
Hong Kong ,
Iran ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Public Policy ,
Russia ,
U.S. Treasury ,
Venezuela ,
Virtual Currency
On September 21, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) levied its first sanctions against a Russian-operated virtual currency exchange involved in ransomware payments and published an...more
9/24/2021
/ Advisory Opinions ,
AML/CFT ,
Anti-Money Laundering ,
Compliance ,
Cryptocurrency ,
Currency Exchange ,
Cybersecurity Information Sharing Act (CISA) ,
Economic Sanctions ,
FinCEN ,
Know Your Customers ,
Office of Foreign Assets Control (OFAC) ,
Ransomware ,
Russia ,
SDN List ,
U.S. Treasury ,
Virtual Currency
On April 29, 2021, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced two settlements of potential civil liability with two companies over their apparent violations of its regulations. The...more
5/7/2021
/ Bureau of Industry and Security (BIS) ,
Civil Monetary Penalty ,
Compliance ,
Department of Justice (DOJ) ,
Due Diligence ,
Economic Sanctions ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Money Transfer ,
Moneygram ,
Non-Prosecution Agreements ,
Office of Foreign Assets Control (OFAC) ,
Pass-Through Entities ,
SAP SE ,
SDN List ,
Settlement ,
Subsidiaries ,
Third-Party Risk ,
Voluntary Disclosure
On April 15, 2021, President Biden signed a new executive order, Blocking Property with Respect to Specified Harmful Foreign Activities of the Government of the Russian Federation, escalating US sanctions against the Russian...more
A new rule effective March 22, 2021 establishes a process for the US Department of Commerce to review commercial transactions between US and foreign parties for certain information and communications technology and services...more
3/23/2021
/ Biden Administration ,
China ,
Covered Transactions ,
Critical Infrastructure Sectors ,
Cross-Border ,
Cuba ,
Foreign Adversaries ,
Hong Kong ,
Interim Final Rules (IFR) ,
Iran ,
Licensing Rules ,
National Security ,
North Korea ,
Russia ,
Safe Harbors ,
Supply Chain ,
Technology ,
Telecommunications ,
U.S. Commerce Department ,
Venezuela
On December 28, 2020, the Department of the Treasury Office of Foreign Assets Control (OFAC) published awaited guidance on the implementation of Executive Order (EO) 13959, “Executive Order on Addressing the Threat from...more
Assets Control (OFAC) and Financial Crimes Enforcement Network (FinCEN) each issued advisories addressing the risks associated with facilitating ransomware payments: the Advisory on Potential Sanctions Risks for Facilitating...more
On August 6, 2020, President Trump issued two nearly parallel executive orders (EOs) targeting the enormously popular apps TikTok and WeChat: Executive Order on Addressing the Threat Posed by TikTok (TikTok EO), and Executive...more
The US government has established new authorities to impose sanctions in response to China’s national security law for Hong Kong, increasing the compliance risks for international banks and other companies that do business in...more
On June 29, 2020, the Commerce Department issued 32 Frequently Asked Questions (FAQs) concerning revision - effective as of the same date - to Part 744.21 of the Export Administration Regulations (EAR). As we discussed in a...more
7/2/2020
/ Bureau of Industry and Security (BIS) ,
China ,
Defense Sector ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Final Rules ,
General Licenses ,
National Security ,
Russia ,
Technology ,
U.S. Commerce Department ,
Venezuela
On May 15, 2020, the US Department of Commerce announced a rule further targeting Chinese telecommunications company Huawei and its chip-making subsidiary HiSilicon for allegedly engaging in “stepped-up efforts to undermine”...more
The COVID-19 pandemic has had profound economic and political effects over the past several months. Increasingly, those effects have led a number of US policymakers, US allies, and others to question certain US sanctions...more
5/5/2020
/ Coronavirus/COVID-19 ,
Economic Downturn ,
Economic Sanctions ,
Human Rights ,
Importers ,
Imports ,
Iran Sanctions ,
Medical Equipment ,
Office of Foreign Assets Control (OFAC) ,
Personal Protective Equipment ,
Trade Relations ,
U.S. Treasury
Yesterday, the US Department of Commerce Bureau of Industry and Security (BIS) promulgated two new rules and issued a new proposed rule:
..A new final rule that will restrict previously permissible exports to China, Russia...more
4/30/2020
/ Bureau of Industry and Security (BIS) ,
China ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
National Security ,
New Rules ,
Proposed Rules ,
Russia ,
U.S. Commerce Department ,
Venezuela
On April 15, 2020, the US Departments of State, the Treasury, and Homeland Security and the Federal Bureau of Investigation issued an unusual joint advisory regarding North Korea’s malign cyber activities. The Advisory offers...more
On April 21, 2020, the US Federal Emergency Management Agency (FEMA) is due to publish a notification of exemptions (Notification) to the restrictions it has recently imposed on the export of five types of personal protective...more
On April 9, 2020, US Customs and Border Protection (CBP) issued a Memorandum to its field operators providing guidance on the implementation of the US Federal Emergency Management Agency’s (FEMA) Temporary Final Rule (TFR)...more
The Trump Administration has imposed new restrictions on exports of personal protective equipment (PPE) pursuant to the Defense Production Act (DPA).
On April 10, 2020, the US Federal Emergency Management Agency (FEMA) is...more
On March 15, European Commission President Ursula von der Leyen announced a new set of export controls that require government authorization for exports of personal protective equipment (PPE) utilized by healthcare providers,...more
On December 13, 2019, the National Security Division (NSD) of the U.S. Department of Justice (DOJ) issued a revised policy regarding voluntary disclosure of export control and sanctions violations by business organizations...more
12/27/2019
/ Amended Regulation ,
Arms Export Control Act ,
Bureau of Industry and Security (BIS) ,
Compliance ,
Cooperation ,
Department of Justice (DOJ) ,
Directorate of Defense Trade Controls (DDTC) ,
Economic Sanctions ,
Enforcement Guidance ,
Export Administration Regulations (EAR) ,
Export Control Reform Act (ECRA) ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
International Emergency Economic Powers Act (IEEPA) ,
ITAR ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Regulatory Standards ,
Voluntary Disclosure ,
Willful Blindness ,
Willful Misconduct
On November 26, the US Department of Commerce issued a long-awaited proposed rule (Proposed Rule) implementing new restrictions designed to protect the US information and communications technology and services (ICTS) supply...more
12/3/2019
/ CFIUS ,
China ,
Comment Period ,
Executive Orders ,
Huawei ,
Information and Communication Technology (ICT) ,
National Security ,
Proposed Rules ,
Supply Chain ,
Telecommunications ,
U.S. Commerce Department