Will 2022 Be the Year of Supply Chain Ethics?
Effective June 21, 2022, in an effort to address forced labor concerns, U.S. law will broadly prohibit imports of products from China’s Xinjiang Uyghur Autonomous Region...more
1/19/2022
/ China ,
Compliance ,
Customs and Border Protection ,
Due Diligence ,
Enforcement ,
Environmental Social & Governance (ESG) ,
Ethics ,
Forced Labor ,
Human Rights ,
Imports ,
Sanctions ,
Supply Chain ,
Tariff Act of 1930 ,
Uyghur Forced Labor Prevention Act (UFLPA) ,
Withhold Release Orders (WROs)
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
On September 14, 2021, the Kingdom of Saudi Arabia’s (KSA’ s) Cabinet of Ministers launched a new Permanent Ministerial Committee for Examining Foreign Investments (CEFI) that would review foreign investments for potential...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
As the Biden Administration commits to crack down on corruption, recent enforcement actions show the DOJ continues a longstanding trend of relying on AML laws and other alternate statutes to prosecute corruption cases, with...more
7/14/2021
/ Anti-Bribery ,
Anti-Corruption ,
Anti-Money Laundering ,
Biden Administration ,
Compliance ,
Corruption ,
Department of Justice (DOJ) ,
Due Diligence ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Popular ,
RICO ,
Travel Act ,
Wire Fraud
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
On 22 March 2021, the EU added 11 Burmese officials responsible for last month’s military coup in Myanmar to its sanctions list. The designations are made in response to “the illegitimate over-throwing of the...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
Summary of the EO -
On January 12, 2021, former President Trump issued an EO on Promoting Small Modular Reactors for National Defense and Space Exploration. The EO directs the Department of Energy (DOE), Department of...more
2/4/2021
/ Aerospace ,
Biden Administration ,
Department of Defense (DOD) ,
Department of Energy (DOE) ,
Energy Sector ,
Executive Orders ,
NASA ,
New Legislation ,
Nuclear Power ,
Technology Sector ,
Trump Administration
On January 13, 2021, U.S. Customs and Border Protection (CBP) issued a withhold-release order (WRO) on all cotton and tomato products from China’s Xinjiang Uyghur Autonomous Region (XUAR) based on information that reasonably...more
On January 10, 2021, then Secretary of State Mike Pompeo designated Ansarallah, an armed militia in Yemen backed by Iran also known as the “Houthis,” as a Foreign Terrorist Organization (FTO) and as Specially Designated...more
On January 19, 2021, the Commerce Department issued an interim final rule to implement the Executive Order on Securing the Information and Communications Technology and Services Supply Chain (E.O. 13873), which was issued on...more
One portion of the National Defense Authorization Act creates a federal beneficial ownership registry, with reporting requirements for corporations, LLCs and “other similar entities.”
The Corporate Transparency Act creates...more
1/7/2021
/ Anti-Money Laundering ,
Compliance ,
Control Test ,
Disclosure Requirements ,
FinCEN ,
Fund Sponsors ,
Investors ,
NDAA ,
Real Estate Development ,
Reporting Requirements ,
Standard Operating Procedures ,
Transparency
New federal requirements in the annual national defense budget reauthorization effectively will end anonymous U.S. shell companies by requiring businesses to disclose 25 percent owners and control persons to a newly created...more
1/6/2021
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Drug Trafficking ,
Financial Institutions ,
FinCEN ,
Fraud ,
Guidance Update ,
Human Trafficking ,
Law Enforcement ,
Patriot Act ,
Penalties ,
Regulatory Requirements ,
Reporting Requirements ,
Shell Corporations ,
Terrorist Acts ,
U.S. Treasury ,
Virtual Currency ,
Whistleblowers
On December 21, the Bureau of Industry and Security (BIS) published a Military End User (MEU) list to further implement the military end user/end use (MEU) rule defined in Section 744.21 of the Export Administration...more
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
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
On November 12, 2020, President Trump issued an Executive Order (E.O.) prohibiting U.S. persons from engaging in any transaction (defined as a “purchase for value”) of publicly traded securities, or transacting in financial...more
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