Last week, the United States government imposed additional restrictions on the imports from, and exports to, Russia. The import changes stem from the Suspending Normal Trade Relations with Russia and Belarus Act, signed into...more
4/14/2022
/ Belarus ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Imports ,
Russia ,
Supply Chain ,
Trade Relations ,
Trade Restrictions ,
Ukraine
Updated as of April 12, 2022 -
It has now been more than 40 days since the start of Putin’s brutal invasion of Ukraine. Today, following the recent revelations of the atrocities committed in Bucha, Ukraine by Russian armed...more
4/13/2022
/ Asset Freeze ,
Belarus Sanctions ,
Economic Sanctions ,
EU ,
Export Controls ,
Financial Transactions ,
G7 ,
General Licenses ,
Investment ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Trading Restrictions ,
UK ,
Ukraine
It has now been more than 40 days since the start of Putin’s brutal invasion of Ukraine. Today, following the recent revelations of the atrocities committed in Bucha, Ukraine by Russian armed forces, the United States – in...more
The recent comprehensive economic sanctions by the U.S. and other nations against Russia has propelled the crypto community onto the geo-political stage in a major way. As with other forms of payment and methods of money...more
With the advent of blockchain technology, vendors are increasingly accepting payments of goods, including artwork, with digital currency. The decentralized nature of digital currency makes it attractive for a lot of reasons,...more
Updated as of February 25, 2022 -
Key Takeaways of OFAC (Treasury) and BIS (Commerce) Actions -
Major Russian Banks Blocked from the U.S. Financial System. Six major Russian banks — VEB, Promsvyazbank (PSB), VTB Bank,...more
Updated as of February 25, 2022 -
Key Takeaways of EU and UK Recent Actions Against Russia and Ukraine Breakaway Regions -
The EU adopted the first tranche of sanctions restrictions targeting financial institutions, other...more
On February 4, the Department of the Treasury published a study on the facilitation of money laundering and terrorist financing through the art trade. Among other considerations, the report discussed the risks of financial...more
2/28/2022
/ Anti-Money Laundering ,
BSA/AML ,
Cryptocurrency ,
Financial Crimes ,
Financial Institutions ,
Financial Transactions ,
FinCEN ,
Money Laundering ,
Non-Fungible Tokens (NFTs) ,
Terrorist Financing ,
U.S. Treasury
U.S. Comprehensive Sanctions Against the DNR and the LNR -
Scope: the DNR and LNR -
The new EO does not detail which parts of the Donetsk and Luhansk regions[1] are subject to the new U.S. sanctions. It is likely that...more
2/22/2022
/ Biden Administration ,
EU ,
Executive Orders ,
Export Administration Regulations (EAR) ,
International Trade ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanctions ,
UK ,
Ukraine ,
United States ,
Vladimir Putin
Today, in a rare demonstration of bipartisanship, the U.S. Senate passed the Uyghur Forced Labor Prevention Act (the “Act”) – the text of which was a compromise between Senator Marco Rubio (R-Fla.) and Representative Jim...more
How do you tackle the complicated and often seemingly insurmountable problem of human rights abuses around the world? The U.S. Government typically uses a variety of tools: diplomatic efforts, international aid, sanctions,...more
The Treasury Department’s Office of Foreign Assets Control (OFAC) took action last Monday, November 8, 2021, and sanctioned a Latvia-based exchange, Chatex, its associated support network, and two ransomware operators for...more
11/17/2021
/ Compliance ,
Cryptocurrency ,
Cyber Crimes ,
Enforcement Actions ,
Financial Transactions ,
Non-Fungible Tokens (NFTs) ,
Office of Foreign Assets Control (OFAC) ,
Ransomware ,
Sanctions ,
SDN List ,
U.S. Treasury
Last Friday, the Office of Foreign Assets Control (OFAC) published more targeted guidance for digital asset companies related to compliance with sanctions and best practices for mitigating risks. This guide comes on the heels...more
10/22/2021
/ Compliance ,
Cryptocurrency ,
Data Management ,
Digital Currency ,
Economic Sanctions ,
Financial Institutions ,
Financial Services Industry ,
Geolocation ,
IP Addresses ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
Ransomware ,
Regulatory Oversight ,
Risk Management ,
Strict Liability ,
Virtual Currency
Today, the United States Trade Representative issued a notice informing the importing community about a new Section 301 exclusion process and seeking comments from affected importers. The comment period begins on October 12,...more
If your company is like many, your board of directors may be demanding that you put more effort into environmental, social, and governance issues, which have become known by the now-ubiquitous acronym “ESG.” Those demands...more
10/11/2021
/ Board of Directors ,
Customs ,
Customs and Border Protection ,
Environmental Social & Governance (ESG) ,
Ethical Standards ,
Exports ,
Forced Labor ,
Imports ,
International Trade ,
Sanctions ,
Supply Chain ,
Trade Policy
Companies are putting forth more effort, thought, commitment, and resources into environmental, social, and corporate governance (ESG) considerations across their business lines. The focus of ESG has primarily centered around...more
On September 21, 2021, the Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions on SUEX OTC, S.R.O, a cryptocurrency exchange, for its role in laundering money to ransomware attackers. According...more
U.S.-Russia relations have been complicated, to say the least. Given Russia’s recent cyberattacks on SolarWinds and the government-directed attempts to influence the 2020 U.S. presidential election, the Biden administration...more
On June 9, 2021, President Biden signed an Executive Order (“EO”) revoking Trump’s orders on TikTok and WeChat. In their stead, President Biden’s EO subjects software applications controlled or owned by “foreign adversaries”...more
6/11/2021
/ Biden Administration ,
Executive Orders ,
Foreign Adversaries ,
Information Technology ,
Mobile Apps ,
National Security ,
Risk Factors ,
Software ,
TikTok ,
Trump Administration ,
WeChat
A June 3, 2021 Executive Order (see our post here) designated 59 Chinese companies in which U.S. companies are prohibited from buying or selling securities. According to the Biden administration, those companies “threaten the...more
6/11/2021
/ Biden Administration ,
China ,
Compliance ,
Executive Orders ,
Foreign Investment ,
Geopolitical Risks ,
Investment Funds ,
Manufacturers ,
Securities ,
Startups ,
Supply Chain
This week has been a week of significant foreign policy action. Today, President Biden issued a new Executive Order imposing tough sanctions on Russia for its interference in the U.S. 2020 presidential election, as well as...more
4/16/2021
/ Biden Administration ,
Cyber Attacks ,
Economic Sanctions ,
Executive Orders ,
Financial Institutions ,
Russia ,
Sanctions ,
SolarWinds ,
Sovereign Debt ,
U.S. Treasury ,
US State Departments
Since President Biden took office and put his national security team in place, we have wondered about the future of the Iran Nuclear Deal. In the past weeks, the Biden Administration has taken formal steps to possibly restore...more
On January 19, 2021, the U.S. Department of Commerce (“DOC”) issued an interim final rule governing transactions in Information and Communication Technology or Services (“ICTS”) involving “foreign adversaries.” Although the...more
On January 13, 2021, U.S. Customs and Border Protection (CBP) issued a Withhold Release Order (WRO) on cotton and tomato products produced by entities operating in Xinjiang, China. The order is based on information that...more
1/27/2021
/ China ,
Customs ,
Customs and Border Protection ,
Due Diligence ,
Enforcement Actions ,
Forced Labor ,
Importers ,
Imports ,
Pending Legislation ,
Supply Chain ,
Withhold Release Orders (WROs)
On August 6, 2020, Trump issued two separate executive orders that will severely restrict TikTok and WeChat’s business in the United States. For weeks, the media has reported on Trump’s desire to “ban” TikTok with speculation...more
8/10/2020
/ Blackmail ,
CFIUS ,
China ,
Data Collection ,
Executive Orders ,
Federal Contractors ,
Federal Employees ,
FIRRMA ,
Geolocation ,
International Emergency Economic Powers Act (IEEPA) ,
Personal Information ,
Popular ,
Secretary of Commerce ,
Social Media ,
TikTok ,
Trump Administration