The government had another busy year in 2023, investigating and prosecuting healthcare fraud cases on multiple fronts. Contending with the enormous healthcare crises of the now-concluded COVID-19 pandemic and the ongoing...more
7/3/2024
/ Anti-Corruption ,
BlackRock ,
Congressional Investigations & Hearings ,
Coronavirus/COVID-19 ,
Department of Justice (DOJ) ,
Educational Institutions ,
Enforcement ,
Enforcement Actions ,
Export Controls ,
False Claims Act (FCA) ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Healthcare Fraud ,
Sanctions ,
Securities and Exchange Commission (SEC) ,
Tennessee
License Exception MED -
On April 25, 2024, the Department of Commerce’s Bureau of Industry and Security (“BIS”) announced a final rule for a new license exception for “medical devices” under § 740.23 of the EAR (“License...more
5/3/2024
/ Belarus ,
Bureau of Industry and Security (BIS) ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exporters ,
Exports ,
General Licenses ,
Licensing Rules ,
Medical Devices ,
Russia ,
Ukraine
This is the tenth in our 2024 Year in Preview series examining important trends in white collar law and investigations in the coming year. Our previous post, "Health Care Fraud Enforcement in 2024," can be found here....more
4/18/2024
/ Bureau of Industry and Security (BIS) ,
Compliance ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
International Trade ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
US Trade Policies ,
White Collar Crimes
On February 23, 2024, the Biden administration announced more than 500 sanctions on individuals and entities inside the Russian Federation and entities outside of Russia determined to be supporting Russia’s war effort....more
On July 26, 2023, the U.S. Department of Justice’s (“DOJ”) National Security Division (“NSD”), the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”), and the U.S. Department of the Treasury’s Office of...more
8/3/2023
/ Bureau of Industry and Security (BIS) ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Financial Crimes ,
FinCEN ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Self-Disclosure Requirements ,
U.S. Commerce Department ,
U.S. Treasury ,
Voluntary Disclosure
On July 16, 2023, Russian President Vladimir Putin signed a decree seizing control of the Russian subsidiaries of the French food-products company, Danone S.A., and Danish brewer, Carlsberg A/S, claiming the assets were being...more
On May 19, 2023, the United States along with other members of the G7 and other allied countries imposed additional sanctions and export controls meant to further restrict Russian economic activity and degrade Russia’s...more
6/5/2023
/ Aircraft ,
Belarus ,
Economic Sanctions ,
Entity List ,
Export Controls ,
Exports ,
Financial Services Industry ,
Office of Foreign Assets Control (OFAC) ,
Research and Development ,
Russia ,
Technology Sector ,
Transportation Industry ,
U.S. Commerce Department ,
Ukraine ,
US Department of State ,
Vessels
On April 6, 2023, Microsoft Corporation (“Microsoft”) agreed to pay $3.3 million to the Department of Commerce’s Bureau of Industry and Security (“BIS”) and the Department of the Treasury’s Office of Foreign Assets Control...more
The centrality of international trade laws in the development and execution of U.S. foreign policy has never been more evident than in 2022. Companies that have not invested in international trade compliance programs are...more
4/21/2023
/ Belarus ,
Biden Administration ,
Bureau of Industry and Security (BIS) ,
CFIUS ,
China ,
Economic Sanctions ,
Enforcement Actions ,
EU ,
Export Controls ,
Financial Services Industry ,
Foreign Direct Investment ,
Human Rights ,
International Trade ,
Iran ,
National Security ,
Nicaragua ,
Russia ,
Trade Restrictions ,
U.S. Commerce Department ,
UK ,
US Department of State ,
Uyghur Forced Labor Prevention Act (UFLPA) ,
Venezuela ,
Virtual Currency ,
Withhold Release Orders (WROs)
Following the initial announcement in September 2022 by the Group of Seven Nations (“G7”) that they would set a price cap on Russian-origin oil and petroleum products, the U.S., the EU, and the UK have moved to implement the...more
I. Additional Export Controls on Russia and Belarus -
(a) Export restrictions on a wide range of EAR99 items -
Effective September 15, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS)...more
9/27/2022
/ Belarus ,
Expiration Date ,
Export Controls ,
Extensions ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Oil Prices ,
Popular ,
Russia ,
SDN List ,
U.S. Commerce Department
I. OFAC Prohibits Gold Importation from the Russian Federation -
Implementing the declaration of G-7 leaders on June 26, 2022, the United States has joined the UK, Canada and Japan in prohibiting the importation of newly...more
June 23, 2022 Key Takeaways: In two recent speeches, Matthew Axelrod, Assistant Secretary for Export Enforcement at the Department of Commerce’s Bureau of Industry and Security (“BIS”), has signaled policy changes related to...more
6/23/2022
/ Antitrust Violations ,
Bureau of Industry and Security (BIS) ,
Department of Justice (DOJ) ,
Disclosure Requirements ,
Enforcement ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Sanctions ,
Self-Disclosure Requirements ,
U.S. Commerce Department
BIS Imposes New Export Controls on Certain Industrial EAR99 Items -
Currently, all items on the Export Administration Regulations’ (“EAR“) Commerce Control List (“CCL”) require a license for export, re-export or transfer...more
6/14/2022
/ Belarus ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Entity List ,
EU ,
Export Controls ,
General Licenses ,
Imports ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
UK ,
Ukraine
I. U.S. Persons Prohibited from Providing Accounting, Trust and Corporate Formation, and Management Consulting Services to Russia -
On May 8, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control...more
U.S. Actions Following increased sanctions on Russian banks and a new Executive Order banning investment in the Russian Federation (reported by Foley Hoag here), on April 7, 2022, the U.S. sanctioned two major Russian...more
I. Biden Administration Import and Investment Ban Related to Russian Energy -
On March 8, 2022, the Biden administration announced its widely anticipated ban on the import of Russian oil and other energy-related...more
3/14/2022
/ Belarus ,
Biden Administration ,
Economic Sanctions ,
Energy Sector ,
EU ,
Export Controls ,
Financial Institutions ,
FinCEN ,
General Licenses ,
Imports ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Russia ,
UK ,
Ukraine
Key Takeaways:
• U.S. imposes additional sanctions on Russian elites, along with their family members, companies, and personal vehicles
• Actions targeting the defense sector and Russian government-affiliated media...more
3/8/2022
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Executive Orders ,
Export Controls ,
Financial Transactions ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
SWIFT ,
Ukraine
On February 28, 2022, the U.S. government announced new sanctions on the Central Bank of Russia, National Wealth Fund, Ministry of Finance, and Russian Direct Investment Fund, dramatically increasing the economic impact of...more
3/2/2022
/ Biden Administration ,
Economic Sanctions ,
Enforcement Priorities ,
Executive Orders ,
Export Controls ,
Financial Transactions ,
Foreign Currency ,
Foreign Trade Regulations ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Ukraine
As we had reported in our earlier client alert and 2022 Year in Preview, Russia’s invasion of Ukraine has resulted in a new wave of sanctions and export controls on Russia, including sanctions on key sectors of the Russian...more
2/28/2022
/ Australia ,
Canada ,
China ,
Economic Sanctions ,
EU ,
Export Controls ,
Exports ,
Financial Institutions ,
Financial Services Industry ,
Japan ,
Licensing Rules ,
New Zealand ,
Russia ,
SDN List ,
Sovereign Debt ,
UK ,
Ukraine ,
Vladimir Putin
This is the fifth post in this year’s series examining important trends in white collar law and investigations. Our previous post discussed trends in State AG enforcement. Up next: SEC Enforcement in 2022: A Look Ahead. ...more
2/25/2022
/ Afghanistan ,
Belarus ,
Biden Administration ,
Bureau of Industry and Security (BIS) ,
Burma ,
Cambodia ,
CFIUS ,
China ,
Cuba ,
Economic Sanctions ,
Enforcement ,
Ethiopia ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Human Rights ,
International Criminal Court ,
Iran Sanctions ,
ITAR ,
Joint Comprehensive Plan of Action (JCPOA) ,
Myanmar ,
Nicaragua ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
SDN List ,
Securities and Exchange Commission (SEC) ,
Sudan ,
U.S. Treasury ,
Uyghur Forced Labor Prevention Act (UFLPA) ,
Venezuela ,
Virtual Currency ,
Withhold Release Orders (WROs)
For months, the Biden administration and the governments of U.S. allies around the world have raised concerns about Russian actions in the region. In the same breath, those governments have warned of massive, coordinated...more
2/18/2022
/ Aerospace ,
Banking Sector ,
Banks ,
Belarus Sanctions ,
Biden Administration ,
China ,
Economic Sanctions ,
Energy Sector ,
EU ,
Export Controls ,
Foreign Direct Product Rule ,
Investment Controls ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
SWIFT ,
UK ,
Ukraine
On Friday, January 28, 2022, U.S. Customs and Border Protection (“CBP”) issued a Withhold Release Order (“WRO”) on disposable gloves produced in Malaysia by TY Industry Holdings Sdn Bhd (“YTY Group”), including YTY Industry...more
On November 3, 2021, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) added two Israeli entities to the Entity List due to malicious cyber activities. In its press release, BIS stated that the...more
11/15/2021
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Cryptocurrency ,
Cyber Crimes ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Interim Final Rules (IFR) ,
Israel ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Sanctions ,
SDN List
In response to a request from the ranking member of the House Foreign Affairs Committee, the Department of Commerce’s Bureau of Industry and Security (BIS) provided export license statistics related to Chinese firms Huawei...more