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Tri-Seal Compliance Note: Voluntary Self-Disclosure of Potential Violations

On July 26, 2023, the departments of Commerce, Justice and the Treasury issued their second ever to date “Tri-Seal Compliance Note” (the “Note”). It describes expectations for the voluntary disclosure of sanctions, export,...more

Russia, China, Semiconductors and Reimagining National Security: US Export Controls 2022 Year in Review

The volume and impact of changes to United States export control regulations in 2022 were unprecedented, and we expect 2023 will likely bring additional changes. This alert provides a summary of key changes, themes and...more

BIS Has New Authorities to Impose Controls over Activities of US Persons in Support of Foreign Military, Security, or Intelligence...

Key Points - The Export Control Reform Act of 2018 has been amended to give BIS the authority to regulate services and other activities of U.S. persons, wherever located, when in support of foreign “military, security, or...more

U.S. Government Imposes Expansive, Novel and Plurilateral Export Controls Against Russia and Belarus

Key Points - As part of highly coordinated U.S. government and allied and partner country responses to Russia’s further invasion of Ukraine, and Belarus’ enabling of it, BIS imposed on February 24, 2022, and March 2,...more

Biden Administration Issues New Sanctions and Export Controls to Respond to Coup in Burma

Key Points - On February 11, 2021, in the first deployment of sanctions since assuming office, President Biden issued EO 14014, authorizing sanctions against members of the Burmese military and related parties responsible...more

New Designations of Chinese Entities Impose Varying Restrictions

The U.S. government has recently imposed controls pertaining to “Communist Chinese Military Companies” (CCMCs or “1237 entities”); Chinese “Military End Users” (MEUs); and Chinese “Military-Intelligence End Users” (MIEUs)....more

New U.S. Sanctions Penalties Spotlight Sanctions and Export Controls Scrutiny of False and Incomplete Statements

• On August 8, OFAC issued Findings of Violation to two U.S. companies in relation to administrative subpoenas with follow-up responses deemed by OFAC to be inaccurate or incomplete. • These recent actions build upon a...more

Waked Money Laundering Organization Sanctions: OFAC Issues General Licenses and Updates

On May 5, 2016, the U.S. Department of Treasury, Office of Foreign Assets Control (OFAC) announced sanctions against 77 entities and individuals associated with the Waked Money Laundering Organization (“Waked MLO,”...more

Tackling a Panamanian Money Laundering Organization: OFAC Sanctions the Waked Money Laundering Organization, Colombia Arrests the...

OFAC Sanctions - On May 5, 2016, the U.S. Department of Treasury, Office of Foreign Assets Control (OFAC) announced sanctions against 77 entities and individuals associated with the Waked Money Laundering Organization...more

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