Episode 302 -- Matt Stankiewicz on DOJ's Massive Criminal Settlement with Cryptocurrency Exchange Binance and its CEO Changpeng Zhao
Polsinelli Podcast - An International Trade Issue That May Impact Your Business
On September 11, 2024, OFAC announced its Interim Final Rule to Extend Recordkeeping Requirements from Five to 10 Years. The Interim Final Rule (IFR) was published in the Federal Register on September 13, 2024. Public...more
Compliance with sanctions regimes has been a priority for debt markets. Amid rising geopolitical tensions, the stakes for lenders and borrowers are higher than ever - Intensifying geopolitical tensions and the US...more
The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) has released updated guidance concerning recent legislation that doubled the statute of limitations for violations of certain sanctions and export control...more
Recent legislation, H.R. 815, the National Security Supplemental (“the Act”) – further explained by guidance issued by the U.S. Department of the Treasury Office of Foreign Assets Control (“OFAC”) on July 22, 2024 – has...more
The U.S. Department of Commerce's Office of Information and Communications Technology and Services (OICTS) within the Bureau of Industry and Security (BIS) issued a Final Determination on June 20, 2024, pursuant to Executive...more
The Department of Commerce’s Bureau of Industry and Security (BIS) published a 13-page Final Determination on June 24, 2024 concerning cybersecurity and antivirus software supplied by a US subsidiary of a Russia-based...more
On April 24, 2024, President Biden signed into law H.R. 815 (Pub. L. 118-50), “Making emergency supplemental appropriations for the fiscal year ending September 30, 2024, and for other purposes” (the “Act”), which includes...more
On April 24, 2024, President Biden signed into law a sweeping national security legislative package that included the 21st Century Peace Through Strength Act, which includes measures to promote sanctions and export controls...more
On April 24, 2024, President Biden signed H.R. 815, otherwise known as the National Security Act of 2024. The bill provides emergency appropriations for Ukraine, Israel, Taiwan, humanitarian purposes in Gaza, and various...more
You are reading the April 2024 Update of the Bass, Berry & Sims Enforcement Roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox. April saw...more
In response to Russia’s invasion of Ukraine, the U.S. government has deployed a whole-of-government approach to impose sanctions and tighter export controls on Russia. This alert summarizes key economic sanctions imposed by...more
On April 24, 2024, President Biden signed into law an emergency supplemental appropriations law, H.R. 815 (Public Law 118-50), that provides substantial military aid to Ukraine, Israel, and Taiwan and could force the sale of...more
On April 24, 2024, President Biden signed into law H.R. 815, the National Security Supplemental (the “Act”). While much of the focus centered on the foreign aid package for Israel, Ukraine, and the Indo-Pacific, the bill...more
On March 6, 2024, the US Departments of Commerce (“Commerce”), Treasury (“Treasury”), and Justice (“DOJ”) released their latest Tri-Seal Compliance Note (“Note”), which focuses on the “Obligations of foreign-based persons to...more
Miami, Florida, U.S.A.- Estlund Law client Dr. Faezeh Faghihi has spent her life in the service of others as a physician in her native Iran and in the United States, her adopted home country. Trained as a gynecologist, she...more
The United States manages more than three dozen separate economic and trade sanctions programs. Those programs target specified foreign governments along with thousands of named individuals, groups and entities in accordance...more
October saw two major enforcement actions involving Russia. First, three individuals were indicted for facilitating the export of controlled U.S.-origin electronics to Russia. Second, the president of a U.S. steel trading...more
August saw two noteworthy Russia-related enforcement actions. First, a dual Russian-German national was arrested and charged with violating the Export Control Reform Act (ECRA) when he allegedly procured microelectronics for...more
United States international trade regulatory agencies have updated voluntary self-disclosure (“VSD”) policies and guidance in an effort to incentivize private sector companies and individuals to self-report violations of U.S....more
May saw several Russia-related enforcement and other actions. The Department of Justice (DOJ) identified and charged three foreign nationals with violating export control laws as they attempted to circumvent Russian...more
Russia - Former Special Agent in Charge of the FBI New York Counterintelligence Division Charged with Violating U.S. Sanctions on Russia (DOJ) Those involved. Charles McGonigal, former Special Agent in Charge of the FBI...more
In connection with recent Russia-related sanctions issued by the US government, organizations face a variety of issues when navigating the questions of who and what transactions may be subject to the reach of these sanctions....more
Over the past week, the Biden Administration has announced unprecedented sanctions and export controls against Russia in response to its unprovoked invasion of Ukraine. As the State Department pledges an additional $350...more
The United States, primarily through Presidential action under the statutory authority of the International Emergency Economic Powers Act (“IEEPA”), has empowered the U.S. Department of the Treasury and its Office of Foreign...more
On November 12, 2020, President Trump issued an Executive Order titled "Addressing the Threat from Securities Investments that Finance Communist Chinese Military Companies," which will prohibit U.S. persons from participating...more