News & Analysis as of

Office of Foreign Assets Control (OFAC) Due Diligence

Benesch

New Statute of Limitations Impacts M&A and International Trade Compliance

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New developments in international trade laws will have tangible and far-reaching impacts on transactions as well as day-to-day business operations.  President Biden’s signing of HR 815 means that once time-barred historic...more

King & Spalding

New Ten-Year Statute of Limitations for Sanctions Violations

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Implications Related to the Doubling of the Statute of Limitations for Civil and Criminal Violations of Two Primary Sanctions Authorities - SUMMARY - On April 24, 2024, President Biden signed into law a foreign military...more

BakerHostetler

Key Export Control Developments During the First Quarter of 2024

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The first quarter of 2024 saw numerous developments on the export control front. This report summarizes the key developments and provides links to the relevant Federal Register notices and/or agency announcements....more

Morrison & Foerster LLP

OFAC Issues Omnibus Accounts Enforcement Case Involving Russia and Other Sanctions Programs

On March 14, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced its first enforcement case of the year and its first ever involving dealings with a Russian designated for sanctions...more

Foley & Lardner LLP

Navigating Global Trade Regulations: Minimizing Supply Chain Risks When Importing from Abroad

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Regulators have sent numerous messages that companies who source from abroad need to subject their entire supply chain to extensive due diligence, based on state-of-the-art compliance measures to minimize supply chain risks....more

Snell & Wilmer

United States Announces Largest Round of Sanctions Since the Start of Russia’s War in Ukraine

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The U.S. Government recently announced the largest round of sanctions against the Russian Federation (Russia) since the invasion of Ukraine two years ago. This multi-agency effort enacted over 500 sanctions against foreign...more

ArentFox Schiff

Navigating the Complexities of Forced Labor Laws: ArentFox Schiff's 2024 Guide for Global Businesses

ArentFox Schiff on

In the last few years, changes to the United States enforcement stance on the forced labor import ban authorized by 19 U.S.C. § 1307 and passage of the Uyghur Forced Labor Prevention Act (UFLPA) have fundamentally changed the...more

American Conference Institute (ACI)

Sanctions Compliance Measures to Mitigate Russia Trade Sanctions Evasion Tactics

The various and elusive tactics used by Russia to evade global sanctions and export controls have grown increasingly sophisticated over the last several months, putting the onus on multinational entities to become equally...more

ArentFox Schiff

Legal Considerations for GCs and CFOs in the Fashion and Retail Industry in 2024

ArentFox Schiff on

The fashion and retail industry experienced another year of considerable change in 2023. As advancements in artificial intelligence (AI) spurred innovation within the industry, consumers and regulators worldwide called for...more

Seward & Kissel LLP

The Importance of Sanctions and Export Control Compliance

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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

Akin Gump Strauss Hauer & Feld LLP

New Executive Order Authorizes the Imposition of Secondary Sanctions on Foreign Financial Institutions Facilitating Russia’s...

Key Points - On December 22, 2023, President Biden issued E.O. 14114 “Taking Additional Steps With Respect to the Russian Federation’s Harmful Activities.” Specifically, E.O. 14114, which amends E.O. 14024 and E.O. 14068,...more

Jenner & Block

Client Alert: How Regulatory Events of 2023 Should Guide Financial Institutions' New Year's Resolutions for 2024

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As consumer-facing financial institutions of all types—from well-established banks to newly-launched fintechs—set their 2024 regulatory compliance goals, they may wonder if their New Year’s resolutions align with those that...more

K2 Integrity

Sanctions Against Russia: U.S. Introduces New Russia-Related Sanctions Targeting Foreign Financial Institutions And Tightens Other...

K2 Integrity on

On 22 December 2023, the Biden administration issued Executive Order 14114, “Taking Additional Steps with Respect to the Russian Federation’s Harmful Activities” (EO 14114), thereby amending EOs 14024 and 14068. The new EO...more

Guidepost Solutions LLC

Innovate or Incriminate: Safeguarding Financial Institutions from Money Laundering Risks

What You Need to Know - In October 2023, the Department of Treasury’s Office of Foreign Asset Control (OFAC) enacted multiple sanctions targeting the supply chain of fentanyl and other illicit drugs. In addition to...more

Ballard Spahr LLP

SEC Exam Priorities Target AML

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Priorities Echo Prior Alerts and Enforcement Actions - The SEC’s Division of Examinations (the “Division”) released on October 16 a report on its “Examination Priorities” (the “Report”) for fiscal year 2024. This release...more

Jones Day

Cryptocurrencies and Risk Under the Antiterrorism Act

Jones Day on

In Short - The Situation: Terrorists may be increasingly turning to cryptocurrencies to evade sanctions and finance terrorist acts, as recent prosecutions and reports suggest. Under the Antiterrorism Act ("ATA"), as...more

Foley & Lardner LLP

What Every Multinational Company Should Know About . . . Supply Chain Integrity

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Both enforcement agencies and consumers increasingly are focused on manufacturers’ supply chains. Human rights enforcement frameworks increasingly have real teeth. Both the United States and the European Union either have, or...more

NAVEX

A Deeper Dive into Human Rights Impact Assessments – Part 1

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Human rights assessments are an increasingly closely watched area of due diligence for the supply chain of organizations across numerous industries. Even smaller operators are subject to the reality of today’s global supply...more

Husch Blackwell LLP

BIS Implements Additional Export Controls and Entity List Additions Targeting Russia to Align with Allies and Partners

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On May 19, 2023, the Department of Commerce’s Bureau of Industry and Security (“BIS”) announced new export controls and Entity List additions during President Biden’s G7 visit in Japan. In conjunction with the G7 meetings,...more

Braumiller Law Group, PLLC

Hot Topics in International Trade - April 2023 - OFAC Enforcement Trends – Lack of Due Diligence in Mergers and Acquisitions

With roughly 12,000 names now associated with the Specially Designated Nationals and Blocked Persons List (“SDN”), layered sanctions on activities with Russia, and growing sanctions on China activities, U.S. sanctions have...more

Holland & Knight LLP

International Trade Compliance Year in Review: 10 Enforcement Lessons from 2022

Holland & Knight LLP on

In the past year, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC), the U.S. Department of Commerce's Bureau of Industry and Security (BIS) and the U.S. Department of State's Directorate of...more

Morgan Lewis

Conducting Effective Sanctions and Anti-Money Laundering Diligence on Non-Latin-Based Entities

Morgan Lewis on

With the ever-increasing use of sanctions as a foreign policy tool (or weapon), sanctions compliance has taken on greater importance than ever. Moreover, as countries increase extraterritorial applications of their sanctions,...more

StoneTurn

The Next Chapter in Sanctions Due Diligence

StoneTurn on

In today’s rapidly changing sanctions landscape, a bare minimum approach to sanctions compliance can leave organizations open to a range of risks that can wreak havoc across their business. Holistic approaches to due...more

Ankura

FinTech Compliance Solutions in the UAE. Revolutionary or Risky?

Ankura on

The UAE is the Middle East’s leading financial center and a global hub for trade, particularly in gold and precious metals. This large presence within the global financial system makes it a target for financial crime,...more

Seward & Kissel LLP

Importance of Timely Sanctions Screening and Due Diligence

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The United States sanctions regime is a complex and ever-changing regulatory space. The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) maintains sanctions lists which are updated in real-time—not on...more

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