So … it’s Christmastime. Which can only mean it’s time for the Christmas tradition that everyone has been waiting for all year! No, I’m not referring to your uncle drinking too much eggnog and falling asleep on the sofa and...more
Both the Biden and the Trump administrations have been expanding U.S. export controls (particularly regarding China) and promulgating new and comprehensive economic sanctions. To reflect the increasing risks of these...more
12/12/2025
/ Bureau of Industry and Security (BIS) ,
China ,
Directorate of Defense Trade Controls (DDTC) ,
Economic Sanctions ,
Export Controls ,
International Trade ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
U.S. Commerce Department ,
U.S. Treasury
As detailed in Part I of this series, the use of international supply chains has suddenly become a lot riskier. In this second part of our series on navigating political instability, we provide some practical coping...more
In 2022, Russia’s invasion of Ukraine triggered a cascade of supply chain disruptions – energy shortages, restricted grain exports, and sweeping sanctions. But the lesson wasn’t just about Russia or war. It was about how...more
On May 23, 2025, approximately five months after the Assad regime was overthrown, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) officially issued Syria General License (GL) 25, which lifted the...more
Mexican cartels dominate large swaths of the Mexico-United States border and the Bajío region (an area encompassing relevant parts of Queretaro, Guanajuato, Aguascalientes, San Luis Potosí, Jalisco, and Michoacán), and they...more
3/7/2025
/ Anti-Money Laundering ,
Compliance ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Foreign Investment ,
International Emergency Economic Powers Act (IEEPA) ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Risk Assessment ,
Risk Management ,
Supply Chain
We have received several requests to publish a list of red flags pertinent to multinational organizations. To accommodate these requests, we are publishing a three-part series on anticorruption, export controls and economic...more
3/21/2024
/ Anti-Corruption ,
Buyers ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Multinationals ,
Regulatory Agenda ,
Risk Management ,
Sellers ,
Supply Chain ,
U.S. Commerce Department
We have received several requests to publish a list of red flags pertinent to multinational organizations. To accommodate these requests, we are publishing a three-part series on anticorruption, export controls and economic...more
3/7/2024
/ Anti-Corruption ,
Antiboycott Requirements ,
Billing ,
Compliance ,
Economic Sanctions ,
Enforcement ,
Ethical Standards ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
Multinationals ,
Recordkeeping Requirements ,
Reputation Management ,
Risk Assessment ,
Risk Mitigation
We have received several requests for a list of the compliance policies that make sense for every multinational company. So, as a follow-up to our earlier two posts providing “twelve steps to international compliance” (see...more
1/4/2024
/ Anti-Corruption ,
Anti-Discrimination Policies ,
Anti-Harassment Policies ,
Anti-Retaliation Provisions ,
Antitrust Provisions ,
Books & Records ,
Code of Conduct ,
Compliance ,
Conflicts of Interest ,
Copyright ,
Customs ,
Cybersecurity ,
Data Protection ,
Document Retention Policies ,
Economic Sanctions ,
Ethics ,
Export Controls ,
Family and Medical Leave Act (FMLA) ,
Forced Labor ,
Foreign Corrupt Practices Act (FCPA) ,
Human Trafficking ,
Imports ,
Insider Trading ,
Internal Controls ,
Litigation Hold ,
Multinationals ,
Popular ,
Privacy Laws ,
Risk Mitigation ,
Social Media ,
Supply Chain ,
Trademarks ,
Uyghur Forced Labor Prevention Act (UFLPA)
In our prior update (published November 29), we provided the first five steps in our twelve-step program for international compliance. These steps are intended to help companies identify international regulatory risk inherent...more
12/14/2023
/ Antiboycott Requirements ,
Audits ,
Compliance ,
Customs ,
Economic Sanctions ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
Internal Controls ,
Policies and Procedures ,
Risk Assessment ,
SDN List ,
Supply Chain ,
Third-Party ,
Training
Record penalties for violations of U.S. regulations governing international conduct and transactions illustrate the risk of costly enforcement actions facing multinational companies. Yet, many multinational companies lack...more
11/30/2023
/ Anti-Corruption ,
Compliance ,
Customs ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Internal Controls ,
International Regulatory Standards ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Risk Assessment ,
Risk Mitigation ,
SDN List ,
Supply Chain ,
UK Bribery Act ,
USML
Did you know that whistleblowers can use the False Claims Act to get the U.S. Government to investigate allegations of lost revenue to the U.S. Treasury, including underpaid Customs tariffs? A large importer recently found...more
11/17/2023
/ Anti-Discrimination Policies ,
CAATSA ,
Compliance ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement ,
Export Controls ,
False Claims Act (FCA) ,
Forced Labor ,
Foreign Corrupt Practices Act (FCPA) ,
Human Trafficking ,
Importers ,
International Trade ,
Revenue ,
Russia ,
Whistleblowers
A veritable grab bag of international trade developments to parse this week. Recent developments include increasing FCPA enforcement, a record OFAC economic sanctions penalty, and a large customs penalty for willful failure...more
10/26/2023
/ Anti-Money Laundering ,
Audits ,
Compliance ,
Customs ,
Duties ,
Economic Sanctions ,
Enforcement ,
Financial Institutions ,
Foreign Corrupt Practices Act (FCPA) ,
International Trade ,
Misclassification ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Valuation
Recent developments include significant antitrust penalties, the issuance of CBP compliance guidance regarding the Uyghur Forced Labor Prevention Act, increasing emphasis on economic sanctions, “the new FCPA,” and the...more
5/25/2023
/ Anti-Corruption ,
Anti-Dumping Duty ,
Compliance ,
Cross Border Privacy Rules (CBPR) ,
Economic Sanctions ,
Enforcement ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
International Trade ,
Non-Compete Agreements ,
Uyghur Forced Labor Prevention Act (UFLPA)
Beginning on February 24, 2022, the U.S. Department of the Treasury Office of Foreign Assets Control (OFAC) and the U.S. Department of State imposed several successive waves of economic sanctions on Russia following the...more
3/3/2022
/ Australia ,
Belarus ,
Bureau of Industry and Security (BIS) ,
Compliance ,
Economic Sanctions ,
EU ,
Executive Orders ,
Export Controls ,
Financial Institutions ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
SWIFT ,
Switzerland ,
UK ,
Ukraine
Earlier this week, the United States, the European Union, Britain, and Canada imposed sanctions on several Chinese officials for human rights abuses against the Uyghur minority in China’s Xinjiang Uyghur Autonomous Region...more
3/25/2021
/ Canada ,
China ,
Economic Sanctions ,
EU ,
Exports ,
Forced Labor ,
Human Rights ,
Office of Foreign Assets Control (OFAC) ,
U.S. Commerce Department ,
U.S. Treasury ,
UK
Welcome to Foley’s new Manufacturing MarketTrends newsletter. In each edition, we will highlight key trends to watch out for in 2019, making it a year of change for manufacturers. ...more
4/18/2019
/ China ,
Cybersecurity ,
Due Diligence ,
Economic Sanctions ,
Manufacturers ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Section 301 ,
Supply Chain ,
Tariffs ,
US Trade Policies
Regulators within the Trump administration have sent a loud message that should concern all multinational automotive companies: laws governing international activities continue to be the subject of intense enforcement...more
5/25/2018
/ Anti-Corruption ,
Automotive Industry ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Extraterritoriality Rules ,
Foreign Corporations ,
Foreign Corrupt Practices Act (FCPA) ,
ITAR ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
Risk Assessment ,
Risk Management ,
SDN List ,
Securities and Exchange Commission (SEC) ,
Supply Chain ,
Trade Policy ,
Trump Administration
Over the last month, regulators with the Trump administration sent a loud message to companies subject to U.S. jurisdiction: Enforcement of laws governing international activities is alive and well and the laws will continue...more
5/14/2018
/ Anti-Corruption ,
Antiboycott Requirements ,
Bribery ,
CEOs ,
CFIUS ,
Chief Compliance Officers ,
Code of Conduct ,
Corporate Counsel ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Subsidiaries ,
Internal Audit Functions ,
Internal Controls ,
ITAR ,
Risk Assessment ,
Risk Management ,
SDN List ,
Securities and Exchange Commission (SEC) ,
Trump Administration
The election of President Trump contained some positive signs for Private Equity (PE) fund managers. These included potential lower corporate taxes, a ten-percent tax holiday for funds parked overseas, large infrastructure...more
4/15/2017
/ Anti-Money Laundering ,
Antitrust Violations ,
CFIUS ,
Criminal Penalties ,
Cybersecurity ,
Dodd-Frank ,
Economic Sanctions ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Foreign Corrupt Practices Act (FCPA) ,
Fund Managers ,
NAFTA ,
Office of Foreign Assets Control (OFAC) ,
Personal Liability ,
Portfolio Companies ,
Privacy Laws ,
Private Equity ,
Risk Assessment ,
Supply Chain ,
Trump Administration ,
Whistleblowers ,
Yates Memorandum
The Trump administration has vowed to bring jobs back to the states. One of the methods it appears it’ll take advantage of is continued, aggressive enforcement of U.S. laws governing exports and international conduct....more
3/1/2017
/ Automotive Industry ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Extraterritoriality Rules ,
False Claims Act (FCA) ,
Foreign Corrupt Practices Act (FCPA) ,
Free Trade Agreements ,
Job Creation ,
Office of Foreign Assets Control (OFAC) ,
Publicly-Traded Companies ,
Supply Chain ,
Trade Policy ,
Trump Administration
Enforcement activity under the Obama administration often made headlines for the eye-popping level of fines, with the Foreign Corrupt Practices Act (FCPA), Anti-Money Laundering (AML) regulations, and economic sanctions...more
2/11/2017
/ Affordable Care Act ,
Anti-Corruption ,
Anti-Money Laundering ,
Attorney General ,
Bribery ,
CFIUS ,
Civil Monetary Penalty ,
Compliance ,
Corporate Crimes ,
Corporate Misconduct ,
Criminal Penalties ,
Criminal Prosecution ,
Cybersecurity ,
Cybersecurity Information Sharing Act (CISA) ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Dual Use Goods ,
Economic Sanctions ,
Employee Training ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Extraterritoriality Rules ,
False Claims Act (FCA) ,
FBI ,
Financial Fraud ,
Foreign Corrupt Practices Act (FCPA) ,
Healthcare Fraud ,
Internal Audit Functions ,
Internal Controls ,
ITAR ,
Multinationals ,
NAFTA ,
Office of Foreign Assets Control (OFAC) ,
Political Appointments ,
Risk Management ,
Risk Mitigation ,
Securities and Exchange Commission (SEC) ,
Terrorist Financing Regulations ,
Trump Administration ,
U.S. Commerce Department ,
Whistleblower Awards ,
White Collar Crimes ,
Yates Memorandum
Who could dislike the title of this post? It promises to solve all your compliance problems and keep your business out of litigation. Were it only that simple.
Of course, it is not. But, when it comes to compliance,...more