The Bureau of Industry and Security (BIS) of the U.S. Department of Commerce announced this past week that it was adding more than three dozen companies to the Entity List effective immediately. This is the second round of...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
1. Treasury Mandates Reporting of Foreign Securities Holdings of $200M or More- All U.S. persons (custodians and end investors) who manage $200 million or more in foreign securities for themselves or others must file a...more
Effective July 2, 2021, as part of the U.S. Government’s ongoing response to the military coup in Burma (Myanmar), the Department of Commerce’s Bureau of Industry and Security (“BIS”) added four entities to the Entity List...more
Effective June 1, 2021, the U.S. Department of the Treasury's Office of Foreign Assets Control (“OFAC”) published new Burmese Sanctions Regulations (“BSR”) that implement President Biden’s February 10, 2021, Executive Order...more
Recently, on April 9, 2021, the US Commerce Department’s Bureau of Industry and Security (BIS) adopted new restrictions targeting Burma by applying Export Administration Regulations’(EAR’s) military-intelligence end-use and...more
On March 25, 2021, the United States imposed sanctions on Myanma Economic Holdings Public Company Limited ("MEHL") and Myanmar Economic Corporation Limited ("MEC"), Burma's two largest military conglomerates. On the same day,...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
On 4 March 2021, the Department of Commerce's Bureau of Industry and Security (BIS) announced that it would impose additional export controls measures on Burma, adding to measures already taken by the Biden administration in...more
U.S. officials have continued to use a range of policy tools to apply pressure on the military leadership of Myanmar (also known as Burma) in response to the military coup in the country and escalating violence against...more
The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued final rules amending the Export Administration Regulations (“EAR”) by implementing new export controls on Burma (Myanmar), and adding four...more
On February 1, 2021, the Myanmar military overthrew the country’s democratically elected government and installed an army general as head of state, with a cadre of military officials and their allies running the government. ...more
On February 1, 2021, the Burmese military announced that it had seized control of the country from the country's democratically elected government.1 In response to the coup, the US has so far designated 12 individuals and...more
Key Points - On February 11, 2021, in the first deployment of sanctions since assuming office, President Biden issued EO 14014, authorizing sanctions against members of the Burmese military and related parties responsible...more
In response to the February 1, 2021, military coup in Burma (Myanmar), on February 10, 2021, President Joe Biden issued Executive Order 14014 (EO 14014), “Executive Order on Blocking Property With Respect to the Situation in...more
On February 11, 2021, the Biden Administration created a new sanctions regime and imposed additional export restrictions in response to the recent military coup in Burma. While the new measures do not broadly prohibit doing...more
On February 11, 2021, President Biden issued Executive Order 14014 of February 10, 2021, “Blocking Property With Respect to the Situation in Burma” (“E.O. 14014”), the first sanctions-related E.O. of his new administration,...more
With the rise of OFAC Sanctions enforcement and compliance issues, companies have to devote significant resources to following changes in OFAC Sanctions. Over the last few years, the US government has significantly altered...more
Overview of US and EU Trade Sanctions - Following is a summary of the current US and EU sanctions that restrict trade with and/or investment in certain countries, “Specially Designated Nationals” (SDNs) and “Blocked...more
We frequently discuss enforcement actions in this blog, because understanding enforcement is a key aspect of trade compliance. From a fifty-thousand foot view, each enforcement case serves as a cautionary tale about the...more