- On April 28, 2020, the Bureau of Industry and Security of the U.S. Department of Commerce announced changes to the Export Administration Regulations (EAR) through three notices published on the Federal Register. The changes...more
4/30/2020
/ Bureau of Industry and Security (BIS) ,
Exceptions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Final Rules ,
General Licenses ,
Licensing Rules ,
Military End Use ,
National Security ,
Proposed Rules ,
U.S. Commerce Department
- On February 18, 2020, OFAC designated Rosneft Trading, S.A. (Rosneft Trading), a subsidiary of Russia-based Open Joint-Stock Company Rosneft Oil Company (Rosneft Oil Company), and its president, Didier Casimiro, on the SDN...more
2/21/2020
/ Blocked Person ,
Crude Oil ,
Economic Sanctions ,
Energy Sector ,
Export Controls ,
Exports ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
SDN List ,
Venezuela
• A new Executive Order signed October 14, 2019, authorizes U.S. sanctions related to the military conflict between Turkey and Syria, providing broad authority to impose sanctions against Turkish government agencies,...more
• The Commerce Department’s Bureau of Industry and Security (BIS) has added 46 additional Huawei affiliates to the Entity List. The export, reexport, and transfer to these entities of commodities, software, and technology...more
8/21/2019
/ Bureau of Industry and Security (BIS) ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Foreign Policy ,
General Licenses ,
Huawei ,
Prohibited Transactions ,
Software ,
Technology Sector ,
Telecommunications ,
U.S. Commerce Department
• In a further escalation of U.S. sanctions on Venezuela in support of its efforts to oust the regime of Nicolás Maduro, on August 5, 2019, the Trump administration imposed comprehensive sanctions on the Government of...more
8/19/2019
/ Banking Sector ,
Blocked Entities ,
Blocked Person ,
Economic Sanctions ,
Executive Orders ,
Financial Institutions ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Trump Administration ,
Venezuela
• On May 20, 2019, the U.S. Department of Commerce published a 90-day Temporary General License (TGL) authorizing limited categories of exports, reexports, or transfers that are otherwise prohibited pursuant to the addition...more
5/22/2019
/ Bureau of Industry and Security (BIS) ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Foreign Policy ,
General Licenses ,
Huawei ,
Manufacturers ,
National Security ,
Prohibited Transactions ,
Supply Chain ,
Technology Sector ,
Telecommunications ,
U.S. Commerce Department
• On May 16, 2019, the U.S. Department of Commerce published a final rule adding Huawei and 68 other companies, mostly its non-U.S. affiliates worldwide, to the Entity List... The rule will be officially published in the...more
5/20/2019
/ Bureau of Industry and Security (BIS) ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Final Rules ,
Foreign Policy ,
General Licenses ,
Huawei ,
National Security ,
Technology Sector ,
U.S. Commerce Department
• On January 28, 2019, OFAC added the Venezuelan state-owned oil and natural gas company PdVSA to its SDN List.
• As a result, U.S. persons are generally prohibited from engaging in transactions with PdVSA and entities that...more
2/6/2019
/ Blocked Person ,
Bonds ,
Capital Markets ,
Debt-Equity ,
Economic Sanctions ,
Energy Sector ,
Executive Orders ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
SDN List ,
Securities Transactions ,
State-Owned Enterprises ,
Trump Administration ,
Venezuela
• As of November 5, 2018, the United States concluded the second of two wind-down periods for re-imposition of U.S. sanctions on Iran following the May 8, 2018, announcement that the United States would cease participation in...more
11/27/2018
/ Aircraft ,
Blocking Statutes ,
Cross-Border Transactions ,
Economic Sanctions ,
EU ,
Exports ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Goods or Services ,
Humanitarian Assistance ,
Imports ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Nuclear Weapons ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Popular ,
SDN List ,
Special Purpose Vehicles ,
SWIFT ,
Trade Policy ,
Trump Administration ,
Vessels
• The U.S. government has withdrawn from the Iran Nuclear Deal and reverted sanctions to the status quo ante by re-imposing secondary sanctions that restrict non-U.S. persons from engaging in a broad range of business in...more
5/10/2018
/ Controlled Foreign Corporations ,
Economic Sanctions ,
Exports ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Trade Policy ,
Trump Administration
Based on certain State Department findings, effective October 12, 2017, long-standing U.S. sanctions on the Republic of Sudan administered by OFAC under the Sudan Sanctions Regulations will be terminated, and U.S. persons...more
10/13/2017
/ Bureau of Industry and Security (BIS) ,
Commerce Control List ,
Commodities ,
Department of Defense (DOD) ,
Economic Sanctions ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Exports ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Secretary of State ,
Sudan ,
Trade Restrictions ,
Trump Administration ,
TSRA
• This enforcement action highlights the heightened sanctions compliance and enforcement risk that companies face when engaging third-party consultants to perform due diligence on counterparties. U.S. persons must make clear...more
8/28/2017
/ Due Diligence ,
Economic Sanctions ,
Enforcement Actions ,
General Licenses ,
Imports ,
IPSA ,
Iran ,
Iran Sanctions ,
ITSR ,
Office of Foreign Assets Control (OFAC) ,
Sanction Violations ,
Settlement
ANTICORRUPTION DEVELOPMENTS -
Las Vegas Sands Corporation Agrees to Pay Approximately $7 Million to Resolve DOJ FCPA Enforcement Action –
On January 19, 2017, Las Vegas Sands Corporation (“Sands”), a Nevada-based...more
ANTICORRUPTION DEVELOPMENTS -
Las Vegas Sands Corporation Agrees to Pay Approximately $7 Million to Resolve DOJ FCPA Enforcement Action –
On January 19, 2017, Las Vegas Sands Corporation (“Sands”), a Nevada-based...more
2/1/2017
/ CFIUS ,
Cuba ,
Disgorgement ,
Economic Sanctions ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
General Licenses ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
Rolls-Royce ,
SCOTUS ,
Suspensions & Debarments ,
World Bank
Key Points -
- Effective today, a new general license reverses two decades of U.S. policy by authorizing all transactions otherwise prohibited by the Sudanese Sanctions Regulations (SSR), including all transactions...more
Former CEO of Harris Corporation’s Chinese Subsidiary Pays $46,000 to Settle Alleged FCPA Violations; No Charges for Company -
On September 13, 2016, the Securities and Exchange Commission (SEC) issued a...more
10/5/2016
/ Airbus ,
Aviation Industry ,
Boeing ,
China ,
Export Controls ,
Film Industry ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Investment ,
General Licenses ,
Iran Sanctions ,
Russia ,
South Korea ,
Subsidiaries
LATAM Airlines Agrees to Pay $22 Million to Settle FCPA Cases -
Last month, LATAM Airlines (“LATAM”), based in Santiago, Chile, agreed to pay $22 million to settle parallel civil and criminal proceedings involving...more
10/4/2016
/ Airbus ,
Aviation Industry ,
Beneficial Owner ,
Boeing ,
Cuban Assets Control Regulations (CACR) ,
Customer Due Diligence (CDD) ,
Deferred Prosecution Agreements ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Narcotics Kingpin Sanctions ,
General Licenses ,
Health Insurance ,
Humana ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
SDN List
LATAM Airlines Agrees to Pay $22 Million to Settle FCPA Cases -
Last month, LATAM Airlines (“LATAM”), based in Santiago, Chile, agreed to pay $22 million to settle parallel civil and criminal proceedings involving...more
10/4/2016
/ Airbus ,
Aviation Industry ,
Boeing ,
Cuba ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Narcotics Kingpin Sanctions ,
General Licenses ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
SDN List
LATAM Airlines Agrees to Pay $22 Million to Settle FCPA Cases -
Last month, LATAM Airlines (“LATAM”), based in Santiago, Chile, agreed to pay $22 million to settle parallel civil and criminal proceedings involving...more
10/4/2016
/ Airbus ,
Aviation Industry ,
Beneficial Owner ,
Boeing ,
Cuban Assets Control Regulations (CACR) ,
Customer Due Diligence (CDD) ,
Deferred Prosecution Agreements ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Narcotics Kingpin Sanctions ,
General Licenses ,
Health Insurance ,
Humana ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
SDN List