The U.S. Congress enacted the Corporate Transparency Act (CTA) in 2020. The CTA for the first time created a federal obligation to report beneficial ownership information for most U.S. entities (and foreign entities doing...more
On 6 November 2023, the Department of the Treasury’s Financial Crimes Enforcement Network and the Department of Commerce’s Bureau of Industry and Security issued a joint notice concerning a new Suspicious Activity Report key...more
Deputy Attorney General Lisa Monaco announces a new safe harbor policy for voluntary self-disclosures of acquired entities’ criminal misconduct. Although the new safe harbor provides clear timelines for disclosure, the costs...more
The US Treasury’s Financial Crimes Enforcement Network (FinCEN) has issued a Small Entity Compliance Guide to aid in understanding and complying with the Corporate Transparency Act’s beneficial ownership information reporting...more
The U.S. Departments of Commerce, Justice and Treasury have issued a “Tri-Seal” Compliance Note regarding national security laws and regulations and the voluntary self-disclosure of potential violations, highlighting...more
8/2/2023
/ Bureau of Industry and Security (BIS) ,
Department of Justice (DOJ) ,
Export Administration Regulations (EAR) ,
Export Controls ,
FinCEN ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Self-Disclosure Requirements ,
U.S. Commerce Department ,
U.S. Treasury ,
Voluntary Disclosure
The US Bureau of Industry and Security has announced that the “Five Eyes” countries have committed to formally coordinate on export controls enforcement. The intelligence alliance member countries hope to increase enforcement...more
The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) clarified its policy regarding voluntary self-disclosures and enforcement actions on April 18, 2023. Historically, a failure to voluntarily...more
On Tuesday April 18, 2023, the U.S. Department of Justice (DOJ) Civil Rights Division’s Immigrant and Employee Rights Section (IER) issued additional guidance regarding compliance with U.S. anti-discrimination laws at the...more
In 2021, the Export Controls and Human Rights Initiative (“ECHRI”) was launched at the first Summit for Democracy as part of the Presidential Initiative for Democratic Renewal. This year, during the Summit for Democracy 2023...more
On 7 March 2023, U.S. Senators Mark Warner and John Thune introduced the Restricting the Emergence of Security Threats that Risk Information and Communications Technology (RESTRICT) Act, sweeping legislation aimed at...more
On 24 February 2023, the U.S. intensified its sanctions on Russia and released new trade control measures targeting key sectors, evasion efforts, and military supplies. Taken together, the additional sanctions, export...more
On February 16, 2023, the Department of Justice (DOJ) and the Department of Commerce (Commerce) announced the creation of a joint Disruptive Technology Strike Force (Strike Force). The Strike Force will be co-led by the...more
3/7/2023
/ Bureau of Industry and Security (BIS) ,
CFIUS ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Export Controls ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Technology Sector ,
U.S. Commerce Department
Through Aerospace & Defense Insights, we share with you the top legal and political issues affecting the aerospace and defense (A&D) industry. Our A&D industry team monitors the latest developments to help our clients stay in...more
The United States Department of Commerce’s Bureau of Industry and Security has issued regulations to amend the Export Administration Regulations to implement changes to controls of certain viruses, marine toxins, plant...more
The U.S. Department of State, Bureau of Political-Military Affairs, Directorate of Defense Trade Controls, which regulates the brokering, export, reexport, retransfer, and temporary import of defense articles and services,...more
On 2 December 2022, the US Department of the Treasury issued a press release announcing a $60/barrel price cap that will apply to the prohibition on US persons from engaging in a broad range of services related to the...more
The International Traffic in Arms Regulations, administered by the U.S. Department of State’s Directorate of Defense Trade Controls, and the Export Administration Regulations, administered by the U.S. Department of Commerce’s...more
The Financial Crimes Enforcement Network’s most recent financial trend analysis report on ransomware-related Bank Secrecy Act filings for 2021 reveals an increased number of ransomware attacks and that a substantial number of...more
The United States government is increasingly scrutinizing U.S. industry’s reliance on China for biotechnology research and development and manufacturing, and is taking steps to expand export control requirements on China that...more
10/24/2022
/ Biotechnology ,
Bureau of Industry and Security (BIS) ,
CFIUS ,
Executive Orders ,
Export Control Reform Act (ECRA) ,
Export Controls ,
FIRRMA ,
National Security ,
Popular ,
Research and Development ,
Technology Sector
The Department of Commerce’s Bureau of Industry and Security has issued an interim final rule to deny China’s access to certain semiconductor and advanced computing technology and to inhibit China’s ability to manufacture...more
On 9 September 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published “Preliminary Guidance on Implementation of a Maritime Services Policy and Related Price Exception for Seaborne...more
The U.S. Government has imposed additional punitive measures against Russia in response to Russia’s actions in Ukraine. The new measures include a prohibition on imports of Russian gold into the United States, new SDN and...more
7/5/2022
/ Blocking Sanctions ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Controls ,
FinCEN ,
Foreign Policy ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
State-Owned Enterprises ,
Supply Chain ,
Ukraine
On 2 June 2022, the U.S. Commerce Department’s Bureau of Industry and Security (“BIS”) issued two final rules, effective on the same day, that revised the Export Administration Regulations (“EAR”) pertaining to the U.S.’s...more
The Office of Foreign Assets Control (“OFAC”) issued General License (“GL”) No. 22 on May 12, 2022, authorizing transactions that are ordinarily incident and necessary to activities that occur in specified, non-regime held...more
On March 31, to address rising energy prices in the U.S. and globally, the Biden administration announced a record release from the Strategic Petroleum Reserve, of roughly one million barrels per day, every day for the next...more