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The Volkov Law Group

Episode 319 -- Deep Dive into SCG Plastics' $20 Million Settlement with OFAC for Violations of the Iran Sanctions Program

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OFAC is capable of extending a long-arm of enforcement, reaching sometimes non-U.S. companies that may “cause” another company to violate U.S. Sanctions laws. If you need to find an example of this long reach, look no...more

Linda Liu & Partners

How Do Trademark Registrants for OEM Production Respond to Cancellation based on Non-use for 3 Consecutive Years?

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In recent years, the number of cancellations based on non-use of trademarks for 3 consecutive years has increased year by year. When submitting use evidence to the CNIPA in response to the cancellation, there is a situation...more

Sheppard Mullin Richter & Hampton LLP

Guidance to Foreign Companies on Export Controls and Sanctions: Departments of Commerce, Treasury, and Justice Issue Tri-Seal...

On Wednesday, March 6, 2024, the Department of Commerce, Department of the Treasury and Department of Justice issued another Tri-seal Compliance Note, focusing this time on the obligations of foreign based persons complying...more

Lowenstein Sandler LLP

Trade Matters - Lowenstein Sandler's Global Trade & National Security Newsletter - October 2023

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1. Seagate Technology Gets Largest-Ever BIS Penalty for Sales to Huawei- Seagate Technology LLC recently incurred a $300 million civil penalty from U.S. Department of Commerce’s Bureau of Industry and Security (BIS) due to...more

Oberheiden P.C.

OFAC Compliance: Avoiding Common Root Causes of Compliance Policy Breakdowns and Deficiencies

Oberheiden P.C. on

For financial institutions and businesses that are subject to the oversight of the Office of Foreign Assets Control (OFAC), compliance needs to be a priority in 2023. OFAC is playing an increasingly active role in overseeing...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – July 2023 Update

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July saw two noteworthy Russia enforcement actions. A Russian national was arrested in Estonia and extradited to the United States after being charged with conspiring to procure U.S.-origin technologies and ammunition on...more

Holland & Knight LLP

Avoiding Pitfalls When Exporting Aircraft from the United States (Updated September 25, 2022)

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Update: This Holland & Knight alert has been updated on Sept. 25, 2022, with additional information. In plain English, anytime an aircraft departs the United States, this is an "export" and will fall in one of two "buckets":...more

Williams Mullen

Outsourcing Manufacturing of Sensitive Items to Foreign Firms Presents Export Control Challenges

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Outsourcing the design and manufacturing of products, components and software to foreign contractors has become a significant part of manufacturing in the U.S. However, if the items involved are subject to U.S. export...more

Perkins Coie

Sanctions Are the New FCPA: US Pledges Enforcement, Issues New Russia Sanctions and Export Controls

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As Russia’s invasion of Ukraine persists, with no end currently in sight, the United States continues to issue increasingly punishing economic sanctions and export controls targeting Russia, most recently aiming at the...more

ArentFox Schiff

Sleeper Trump Rule on ‘Military-Intelligence End Uses or Users’ Goes Into Effect

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Companies should be prepared to conduct additional due diligence for any transactions involving entities in the countries enumerated in this rule. In an interim rule published on, January 15, 2020, the Department of...more

Sheppard Mullin Richter & Hampton LLP

Certainties and Uncertainties Under China’s New Unreliable Entity List

On September 19, 2020, China took a new strategic position in its ongoing trade confrontation with the United States. The Ministry of Commerce of the PRC (“MOFCOM”) issued Regulations on Unreliable Entity List (“UEL”) and...more

Pillsbury Winthrop Shaw Pittman LLP

China’s Ministry of Commerce Publishes “Unreliable Entity List” Provisions

On September 19, 2020 (September 18, 2020 U.S. EDT), China’s Ministry of Commerce (MOFCOM) published the Provisions on the Unreliable Entity List (UEL Provisions), which took effect on the same date. On May 31, 2019,...more

Akin Gump Strauss Hauer & Feld LLP

DDTC Publishes New FAQs on Defense Services Performed by U.S. Persons Abroad and How to Get Them Approved via GC

• On January 6, 2020, DDTC published a new FAQ on Defense Services Performed by U.S. Persons Abroad, confirming that the ITAR regulate defense services performed by a U.S. person employed by a non-U.S. company outside of the...more

Hogan Lovells

BIS targets alleged human rights violations by expanding Entity List with addition of 28 Chinese parties

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On 7 October 2019 the U.S. Department of Commerce's Bureau of Industry and Security (BIS) expanded the Entity List, restricting certain transactions with 28 Chinese entities. ...more

Akin Gump Strauss Hauer & Feld LLP

Commerce Adds 50 Foreign Entities to the Unverified List (and Removes 10)

• The Commerce Department’s Bureau of Industry and Security (BIS) has added 50 entities to its Unverified List (UVL). Thirty-seven of the newly listed entities are in China. BIS also removed 10 entities from the list that had...more

Morgan Lewis

“Implementation Day” Arrives, Triggering Relaxation of US Sanctions against Iran

Morgan Lewis on

The impact of Implementation Day will vary depending on whether you are a US Person, a US-owned or controlled Foreign Entity, or a Foreign Person with no US nexus—what’s your status? ...more

Baker Donelson

Is Iran Open for Business for U.S. Exporters?

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On August 7, 2015, the U.S. Government issued a revised Guidance regarding Iran and also issued a Third Amended Statement of Licensing Policy on Activities Related to the Safety of Iran’s Civil Aviation Industry. The bottom...more

BakerHostetler

The Nuclear Deal With Iran: The Lifting of Sanctions and Implications for Business

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On July 14, 2015, after two years of sometimes intense negotiations, the United States, the United Kingdom, France, Germany, Russia, and China (known as the “P5+1” countries), along with the European Union, signed a Joint...more

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