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Now Including the Kitchen Sink: Expansion of Export Controls on Russia Adds Restrictions on Low-Level Items and Software

Last year, we published an update on BIS’s foray into prohibiting EAR99 items for export to Russia and Belarus. We noted (somewhat in jest) that kitchen sinks may one day be added. Well, that day has come. Stainless steel...more

Guidance to Foreign Companies on Export Controls and Sanctions: Departments of Commerce, Treasury, and Justice Issue Tri-Seal...

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

Everything but the Kitchen Sink (and Maybe That Too!): New Export Controls on Russia Cover Whole Categories of Low-Level...

The United States and its allies are aiming to choke off the supplies that support the last vestiges of Russian industry. On May 19, 2023, the Bureau of Industry and Security (BIS) released new regulations implementing...more

OFAC Finds Digital Assets Trading Platform in Violation of Sanctions

On March 31, 2023, the Office of Foreign Assets Control (OFAC) announced a $72,230.32 settlement agreement with Uphold HQ Inc. (Uphold), a global multi-asset digital trading platform, in connection with 152 apparent...more

Friday Development: New Sanctions and Export Controls to Address Russia’s Ongoing Aggression in Ukraine (Including the use of...

In response to Russia’s ongoing aggression in Ukraine, both the United States and the European Union have imposed additional sanctions and further restricted exports to Russia and Iran. These new controls span many...more

OFAC Issues Sanctions Compliance Guidance for Instant Payment Systems

On September 30, 2022, the Office of Foreign Assets Control (OFAC) published compliance guidance for instant payment systems. The guide highlights the need for emerging payment technology companies to assess their sanctions...more

OFAC Announces Hefty Settlement with Virtual Currency Exchange / Hosted Wallet Services Provider

Settlement Agreement with Bittrex, Inc. Today, on October 11, 2022, the Office of Foreign Assets Control (OFAC) announced a $24,280,829.20 settlement agreement with Bittrex, Inc., an online virtual currency exchange and...more

U.S. and Allies Impose Additional Russia Sanctions After Sham Annexations

In response to Russia’s illegal declaration of annexations of Ukrainian territory, the United States and the European Union have imposed additional sanctions on Russia. U.S. Response On October 4, 2022, the U.S. government...more

Novel Sanctions Against Business-Related Services Connected to Russia and Additional Export Restrictions

On Sunday, the Department of Treasury’s Office of Foreign Assets Control (OFAC) announced novel and sweeping sanctions on specific categories of services in order to cripple Russia’s wartime capabilities and sanctioned key...more

Additional Import and Export Restrictions in Response to Russia’s Aggression in Ukraine

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

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