On December 11, the Department of Justice, the Department of Commerce’s Bureau of Industry and Security (BIS), the Department of Homeland Security, the Department of State’s Directorate of Defense Trade Controls (DDTC), and...more
1/12/2024
/ Bad Actors ,
Bureau of Industry and Security (BIS) ,
China ,
Compliance ,
Coronavirus/COVID-19 ,
Department of Homeland Security (DHS) ,
Department of Justice (DOJ) ,
Directorate of Defense Trade Controls (DDTC) ,
Economic Sanctions ,
Executive Orders ,
Foreign Financial Institutions (FFI) ,
Foreign Subsidiaries ,
Iran Sanctions ,
Nasdaq ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Supply Chain ,
Tariffs ,
U.S. Commerce Department ,
Virtual Currency
On Oct. 4, Deputy Attorney General Lisa Monaco (DAG Monaco) announced a new safe harbor policy for voluntary self-disclosures made in connection with mergers and acquisitions (the Safe Harbor Policy). At the outset of her...more
1. FinCEN and BIS Target Financial Institutions for Export Compliance-
On June 28, the Financial Crimes Enforcement Network (FinCEN) and the Bureau of Industry and Security (BIS) issued their first joint alert urging...more
8/9/2022
/ Bureau of Industry and Security (BIS) ,
China ,
Compliance ,
Crypto Exchanges ,
Economic Sanctions ,
Exports ,
FinCEN ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Ransomware ,
Russia ,
Ukraine ,
USTR
Export control requirements, economic sanctions, foreign ownership rules, import restrictions — cross-border trade continues to get more complex.
Do you know there are trade laws that restrict who you can do business...more
10/22/2021
/ Blocked Entities ,
CFIUS ,
Compliance ,
Cross-Border ,
Customs and Border Protection ,
Duties ,
Economic Sanctions ,
Embargo ,
Export Controls ,
Foreign Entities ,
Foreign Investment ,
Foreign Ownership ,
Foreign Workers ,
Imports ,
National Security ,
Startups ,
Tariffs ,
Technology Sector ,
Trademark Infringement
1. Recent Enforcement: Even Companies That Invest in Compliance Pay Penalties-
Since our April enforcement roundup, the Office of Foreign Assets Control (OFAC) and the Bureau of Industry and Security (BIS) in the Department...more
6/3/2021
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
China ,
Compliance ,
Critical Infrastructure Sectors ,
Cybersecurity ,
Department of Justice (DOJ) ,
ENERGY STAR Program ,
Enforcement Actions ,
Executive Orders ,
Export Controls ,
Exports ,
Geo-Blocking ,
Honeywell International ,
ITAR ,
Moneygram ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Sanctions ,
SDN List ,
Software ,
U.S. Commerce Department ,
U.S. Treasury
Summaries of recent legislative and regulatory developments with respect to:
•The SEC’s Examination Priorities for 2021-
•The SEC’s Focus on Digital Asset Securities-
•The SEC’s New Marketing Rule... ...more
4/1/2021
/ Accredited Investors ,
Anti-Money Laundering ,
BEA ,
Broker-Dealer ,
CARES Act ,
CFIUS ,
Chief Compliance Officers ,
Client Funds ,
Common Reporting Standard (CRS) ,
Compliance ,
Coronavirus/COVID-19 ,
Department of Justice (DOJ) ,
Digital Assets ,
Disclosure ,
Employee Retirement Income Security Act (ERISA) ,
Environmental Social & Governance (ESG) ,
EU ,
Financial Fraud ,
Financial Industry Regulatory Authority (FINRA) ,
FinTech ,
Foreign Investment ,
Form CRS ,
General Data Protection Regulation (GDPR) ,
IARD ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
Investment Portfolios ,
Net Operating Losses ,
Office of Foreign Assets Control (OFAC) ,
Recordkeeping Requirements ,
Registered Investment Advisors ,
Safe Harbors ,
SEC Examination Priorities ,
Securities and Exchange Commission (SEC) ,
Tax Cuts and Jobs Act ,
U.S. Treasury ,
Unauthorized Transactions
On November 19, 2020, the Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (OCIE) released a risk alert (the Risk Alert) identifying common compliance issues related to Rule 206(4)-7 (the...more
12/7/2020
/ Anti-Corruption ,
Compliance ,
Department of Justice (DOJ) ,
Fund Managers ,
Investment Adviser ,
OCIE ,
Office of Foreign Assets Control (OFAC) ,
Registered Investment Advisors ,
Risk Alert ,
Securities and Exchange Commission (SEC) ,
U.S. Treasury
As trade compliance gains more traction, US regulators have made it clear that having compliance policies in place is critical, regardless of the company size or the industry. The implementation of such compliance programs...more
11/9/2020
/ Bureau of Industry and Security (BIS) ,
Commerce Control List ,
Compliance ,
Cuba ,
Department of Justice (DOJ) ,
ECCNs ,
Export Administration Regulations (EAR) ,
Fines ,
National Security ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Risk Mitigation ,
Sanction Violations ,
Shipping Cargo
Trade compliance programs save manufacturers of goods with overseas supply chains thousands of dollars in duties, fines, and penalties.
According to a 2019 federal study, President Donald Trump’s tariffs and subsequent...more
10/23/2020
/ Audits ,
Commerce Control List ,
Compliance ,
ECCNs ,
Fines ,
Office of Foreign Assets Control (OFAC) ,
Risk Mitigation ,
Section 301 ,
Supply Chain ,
Tariffs ,
Trump Administration ,
US Trade Policies
With "compliance" being the buzzword for corporate executives and legal counsel, there is renewed focus on reducing legal risks when exporting or selling overseas. The key is a robust compliance program that outlines the...more
7/30/2020
/ Bribery ,
Buy-In Agreements ,
Chief Compliance Officers ,
Compliance ,
Compliance Management Systems ,
Exports ,
Foreign Corporations ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Partner ,
Foreign Workers ,
Office of Foreign Assets Control (OFAC) ,
Standard Form Contracts ,
Technology Transfer Agreements
Over the past few years, U.S. regulators have made it clear that having comprehensive and effective compliance policies covering trade is a must, regardless of the company size, location or industry. The government’s move to...more
3/26/2020
/ Bureau of Industry and Security (BIS) ,
Compliance ,
Criminal Penalties ,
Economic Sanctions ,
Enforcement Actions ,
Exports ,
Huawei ,
Imports ,
Multinationals ,
Office of Foreign Assets Control (OFAC) ,
Risk Assessment ,
Risk Mitigation