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Voluntary Self-Disclosure: Is the Value Self-Evident?

How should companies think about DOJ, BIS and OFAC voluntary disclosure in the wake of the DOJ’s massive investment in sanctions and export control enforcement? The DOJ, BIS and OFAC released a joint compliance note...more

Russia Sanctions Year in Review: Impact on Aviation Sector

This post marks the third entry in our Year-in-Review series. For prior posts, click here. Many of the first measures that the United States, European Union and United Kingdom collectively took against Russia in 2022 related...more

Russia Sanctions Year in Review: Impact on Energy Sector

This post marks the second entry in our Year-in-Review series. For prior posts, click here. Few sectors have been more affected by the sanctions on Russia than the energy industry....more

Russia Sanctions Year in Review: Impact on Financial Services Sector

On February 24, 2022, the United States (U.S.), European Union (EU), United Kingdom (UK), and other countries issued a barrage of sanctions against the Russian financial sector, cutting off many major banks from the global...more

Implementing the Russian Oil Price Cap – Most Recent U.S. Guidance

On December 5, 2022, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) announced a $60 per barrel price cap on maritime transfers of Russian-origin crude oil. The final cap level is being implemented...more

U.S. Government Further Targets Nicaragua’s Mining and Gold Sector, and Issues Expanded Executive Order with Broad Trade and...

On October 24, 2022, the U.S. Department of Treasury Office of Foreign Assets Control (OFAC) and Department of State (State) announced new sanctions designations for Nicaragua, targeting a key state mining company and...more

U.S. Commerce Department Imposes Sweeping China-Related Export Controls on Advanced Computing and Semiconductor Manufacturing...

On October 7, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued an interim final rule (the “Rule”) imposing sweeping new export controls targeting certain advanced computing integrated...more

New Sanctions and Export Controls in Global Response to the Attempted Annexation of Ukrainian Territory

In the final few days of September, the U.S. and global allies issued a number of sanctions and export controls against actors who have supported Russia’s referendums in Ukraine and related attempts to annex four Ukrainian...more

U.S. Commerce Department Implements Export Controls on Four New Emerging and Foundational Technologies

On August 15, 2022, the Department of Commerce’s Bureau of Industry and Security (BIS) published an interim final rule introducing new controls on four “emerging and foundational technologies” that were identified during the...more

Further Sanctions Issued Against Russia: Services, Export Controls and Visa Restrictions

On May 8, 2022, the White House announced a number of new measures in response to Russia’s ongoing war in Ukraine. The new measures include prohibitions on new categories of services to Russia by U.S. persons; export controls...more

Recent U.S. Sanctions and Export Control Measures Imposed Against Russia

In the last month, the United States and global allies have issued unprecedented sanctions against Russia in response to the war in Ukraine. These sanctions apply ever-expanding pressure on the Russian economy and touch...more

BIS Hits Russia and Belarus with Sweeping New Export Control Restrictions

On February 24, 2022, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) issued a final rule effective immediately imposing sweeping export control restrictions against Russia in response to Russia’s...more

Russia Invades and the West Reacts: U.S. Government Intensifies Sanctions and Export Controls Against Russia

On February 24, 2022, the U.S. Government issued a number of sanctions measures in response to Russia’s attack on Ukraine. These measures include sweeping financial sanctions and stringent export controls, which will have...more

Commerce Imposes New Export Controls on Cybersecurity Items and Adds a Corresponding License Exception

On October 21, 2021, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) announced an interim final rule (Interim Rule), which will amend the Export Administration Regulations (EAR) to add controls for the...more

Myanmar Update: U.S., UK and EU Continue to Expand Sanctions for Companies with Ties to the Military

U.S., UK and EU authorities continue to expand sanctions targeting the Tatmadaw, Myanmar’s armed forces, following the February 17, 2021, military coup in Myanmar (also known as Burma). Over the past month, the United States...more

U.S. Government Continues to Ratchet Up Pressure Against Myanmar – The Latest Steps

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 Coup in Myanmar — U.S. Announces Initial Response with Targeted Sanctions and Export Controls

In response to the recent military coup in Myanmar (also known as Burma) against the democratically-elected government, on February 11, 2021 the Biden Administration issued an Executive Order on Blocking Property with Respect...more

New U.S. Sanctions Target Turkey’s Defense Sector

On December 14, 2020, the U.S. Department of State initiated a series of sanctions pursuant to Section 231 of the Countering America’s Adversaries Through Sanctions Act (CAATSA) that target the Turkish Presidency of Defense...more

U.S. Government Issues Human Rights Policy for Export Licensing and Guidance to Prevent Misuse of Surveillance Tools

Over the course of the Obama and Trump administrations, U.S. officials have found new ways to incorporate human rights concerns into sanctions and export control policies. Recent announcements by the Commerce and State...more

U.S. Commerce Department Announces Prohibited Transactions Related to WeChat and TikTok But Implementation Is Delayed

On September 18, 2020, the U.S. Commerce Department published two rules defining the scope of prohibited transactions related to the mobile applications, WeChat and TikTok. The scope of prohibited transactions clarified the...more

Sudan Update: OFAC Issues Guidance Clarifying Status of U.S. Sanctions and Export Controls

On August 11, 2020, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a new guidance document, the Sudan Program and Darfur Sanctions Guidance (“Sudan Guidance”), which clarifies the current...more

U.S. Commerce Department Imposes New Restrictions on Huawei

On August 17, 2020, the U.S. Department of Commerce Bureau of Industry and Security (BIS) made available for public inspection a final rule expanding restrictions on Huawei Technologies Co., Ltd. and its non-U.S. affiliates...more

The United States No Longer Considers Hong Kong Autonomous from China, Setting the Stage for Rule Changes that Could Disrupt Trade...

Since the handover of Hong Kong by the United Kingdom to China in 1997, Hong Kong has enjoyed separate treatment from the mainland by the United States, other countries and international organizations pursuant to the “one...more

6/1/2020  /  China , Export Controls , Hong Kong , Imports
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