Earlier this week, the U.S. Office of Foreign Assets Control (OFAC) and the UK Office of Financial Sanctions Implementation (OFSI) published a Memorandum of Understanding (MoU), which was previously signed on October 9, 2024,...more
New Tri-Seal Compliance Note highlights sanctions and export control compliance expectations for non-U.S. persons.
Three agencies overseeing U.S. trade law compliance provided an overview of where U.S. sanctions and export...more
3/27/2024
/ Compliance ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Financial Transactions ,
Foreign Corporations ,
Foreign Direct Product Rule ,
Foreign Jurisdictions ,
Know Your Customers ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Risk Assessment ,
Risk Mitigation ,
Trade Relations ,
U.S. Commerce Department ,
U.S. Treasury
On November 6, 2023, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) announced a $206,213 settlement with Swift Prepaid Solutions, Inc. d/b/a daVinci Payments (daVinci) for apparent violations of...more
Following the October 7 attack on Israel by Hamas, the Treasury Department’s Office of Foreign Assets Control (OFAC) has undertaken several initial sanctions steps to counter terrorist financing and call attention to...more
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
8/4/2023
/ Bureau of Industry and Security (BIS) ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Embargo ,
Enforcement ,
Export Controls ,
FinCEN ,
Foreign Corrupt Practices Act (FCPA) ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Self-Disclosure Requirements ,
White-Collar Exemptions
In a new enforcement action against GM, the Department of Justice (DOJ) Civil Rights Division emphasizes that employers subject to export control obligations must still comply with federal laws against discrimination on the...more
5/23/2023
/ Anti-Discrimination Policies ,
Civil Monetary Penalty ,
Civil Rights Act ,
Compliance ,
Department of Energy (DOE) ,
Department of Justice (DOJ) ,
E-Verify ,
Employment Eligibility Verification ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Form I-9 ,
Immigration and Nationality Act ,
Office of Foreign Assets Control (OFAC) ,
Reporting Requirements ,
Title VII
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
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
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
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
Despite months of posturing and growing geopolitical tensions, Russia’s full-scale invasion of Ukraine this week was a shock to the global community. Western leaders have been swift and unanimous in their response, condemning...more
2/28/2022
/ Anti-Money Laundering ,
Asset Freeze ,
Biden Administration ,
Bureau of Industry and Security (BIS) ,
ECCNs ,
Economic Sanctions ,
EU ,
Executive Orders ,
Export Administration Regulations (EAR) ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
UK ,
Ukraine
On February 24, 2022, in response to Russia’s attack on Ukraine, President Biden announced further sanctions on Russian individuals and entities. These measures are in addition to those already announced on February 22 and 23...more
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
2/25/2022
/ Biden Administration ,
Blocked Entities ,
Blocked Person ,
Economic Sanctions ,
Embargo ,
Export Controls ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
U.S. Treasury ,
Ukraine
On February 22 and 23, 2022, President Biden announced further sanctions in response to Russia’s invasion of Ukraine. These sanctions build upon the U.S. sanctions issued on February 21, 2022. Specifically, the additional...more
On August 9, 2021, the one-year anniversary of the claimed reelection of Belarusian leader Aleksandr Lukashenka, President Biden issued an “Executive Order on Blocking Property of Additional Persons Contributing to the...more
The Biden Administration has signaled an expanded commitment to longstanding U.S. anti-corruption policies, and recent enforcement actions and policy announcements provide insights into what foreign officials, companies and...more
E.O. 14032 signals that the Biden Administration will continue to restrict U.S. investments into China’s defense and surveillance technology sectors.
The prior Administration’s November 2020 Executive Order (E.O.) 13959...more
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
On April 15, 2021, the U.S. Government announced broad new sanctions authorities that can be used to target Russia and implemented limitations on dealings in Russian sovereign debt. These measures were imposed pursuant to a...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
On March 2, 2021, the U.S. Department of the Treasury’s Office of Asset Controls (OFAC) imposed sanctions on two key militant leaders of the Iranian-backed Ansarallah, also known as the Houthis. OFAC sanctions target Mansur...more
On February 18, 2021, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) entered into a settlement of $507,375 with BitPay, Inc. (BitPay) for violations of multiple U.S. sanctions programs. According to...more
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
On December 2, 2020, U.S. Customs and Border Protection (CBP) issued an import detention or Withhold Release Order (WRO) against cotton produced by Xinjiang Production and Construction Corps (XPCC) based on information that...more
Continuing its “maximum pressure” campaign against Iran, the United States has (a) ratcheted up sanctions under Executive Orders that provide for the imposition of secondary sanctions on non-U.S. companies that engage in...more