On Wednesday, March 6, 2024, the Department of Commerce, Department of the Treasury and Department of Justice issued another Tri-seal Compliance Note, focusing this time on the obligations of foreign based persons complying...more
3/8/2024
/ China ,
De Minimis Claims ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Foreign Entities ,
Russia ,
Sanctions ,
U.S. Commerce Department ,
U.S. Treasury
On December 13, 2023, CoinList Markets LLC (“CoinList”) agreed to pay $1,207,830 pursuant to a settlement agreement with the Office of Foreign Assets Controls (“OFAC”) in connection with allegations that the San Francisco...more
Yesterday, on November 28, 2022, the Office of Foreign Assets Control (OFAC) announced a $362,158.70 settlement agreement with Payward, Inc. (Kraken), an online virtual currency exchange, in connection with 826 apparent...more
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
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
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
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
Since the U.S. Government determined that Russia interfered in the 2016 election, movement around Russia sanctions policy has been vigorous, if not unidirectional. In 2016, the United States implemented twice sanctions...more
2/9/2018
/ CAATSA ,
Defense Sector ,
Financial Institutions ,
Foreign Policy ,
Foreign Relations ,
National Security ,
Privatization ,
Russia ,
Sanctions ,
Secondary Sanctions ,
US Department of State
After the announcement of Fidel Castro’s death on November 26, 2016, President Barack Obama sent a message to the Cuban people highlighting his administration’s efforts to improve relations between the United States and Cuba....more
We frequently discuss enforcement actions in this blog, because understanding enforcement is a key aspect of trade compliance. From a fifty-thousand foot view, each enforcement case serves as a cautionary tale about the...more
7/16/2014
/ Aerospace ,
Bureau of Industry and Security (BIS) ,
Burma ,
Enforcement ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Exports ,
Fokker ,
Iran ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Sanctions ,
Settlement ,
Sudan ,
Trade Policy
As we continue to find new ways to look at the implications of the Ukraine-related sanctions introduced by the United States over the past few months, we have shifted our perspective to the extra-terrestrial to focus on the...more