On May 3, 2022, the SEC’s Division of Corporation Finance (“CorpFin”) issued guidance reminding companies with disclosure obligations under U.S. securities laws to be cognizant of any disclosures that may be warranted as a...more
On March 24, 2022, the United States designated additional parties as sanctions targets in Russia in response to the conflict in Ukraine. Companies should continue to conduct restricted party screening of all parties involved...more
In addition to compliance considerations under US sanctions associated with activities of U.S. persons, companies should also ensure that their compliance programs take into account the expansion under U.S. export controls of...more
12/13/2021
/ Burma ,
Cambodia ,
Chemical Weapons ,
Chief Compliance Officers ,
China ,
Compliance ,
Defense Sector ,
Export Administration Regulations (EAR) ,
Export Controls ,
Military End Use ,
National Security ,
Nuclear Weapons ,
Prohibited Transactions ,
Russia ,
U.S. Commerce Department ,
Venezuela
On September 27, 2021, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of Treasury announced a $1,423,766 settlement with Houston-based supplier, Cameron International Corporation (“Cameron”) to resolve...more
11/9/2021
/ Compliance ,
Corporate Counsel ,
Economic Sanctions ,
Enforcement Actions ,
Executive Orders ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanction Violations ,
SDN List ,
Settlement Negotiations ,
Ukraine
U.S. and multinational companies with business involving China should be on the alert given recent changes in U.S. export controls and sanctions. During the months of June and July this year, the U.S. government has taken...more
9/2/2021
/ Biden Administration ,
China ,
Compliance ,
Economic Sanctions ,
Executive Orders ,
Export Controls ,
Hong Kong ,
Multinationals ,
National Security ,
SDN List ,
Supply Chain ,
Trump Administration
On June 7, 2021, US Department of Commerce, Bureau of Industry and Security (“BIS”) amended its Antiboycott provisions in Part 760 of the Export Administration Regulations (“EAR”) easing reporting requirements and business...more
On April 29, 2021, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of Treasury, and the Bureau of Industry and Security (“BIS”) of the U.S. Department of Commerce announced settlements with German...more
5/26/2021
/ Attorney General ,
Bureau of Industry and Security (BIS) ,
Civil Monetary Penalty ,
Compliance ,
Corporate Counsel ,
Data Blocking ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Geo-Blocking ,
Geolocation ,
Germany ,
Iran ,
Iran Sanctions ,
ITAR ,
ITSR ,
Office of Foreign Assets Control (OFAC) ,
SAP SE ,
Settlement ,
Technology Sector ,
U.S. Treasury
Shortly before the end of his term, the Trump Administration made changes to the List of State Sponsors of Terrorism, removing Sudan and putting Cuba back on.
What do the changes mean for Sudan? With the sanctions...more
In addition to the many changes targeted specifically at national security concerns related to China, Russia, and Venezuela, the Bureau of Industry and Security (“BIS”) has implemented a number of additional regulatory...more
11/9/2020
/ Bureau of Industry and Security (BIS) ,
Censorship ,
China ,
Compliance ,
Excessive Force ,
Export Controls ,
Exports ,
Final Rules ,
Hong Kong ,
Human Rights ,
Licensing Rules ,
National Security
While the pandemic has slowed down many things this year, it did not impede progress by the Department of Commerce’s Bureau of Industry and Security (“BIS”) in publishing various regulatory changes aimed at addressing...more
11/4/2020
/ Amended Regulation ,
Bureau of Industry and Security (BIS) ,
China ,
Compliance ,
Department of Defense (DOD) ,
Export Administration Regulations (EAR) ,
Foreign Direct Product Rule ,
Licensing Rules ,
Military End Use ,
National Security ,
Russia ,
Venezuela
On December 13, 2019, the US Department of Justice (DOJ) issued an update to its 2016 guidance regarding enforcement in export control and sanctions investigations of businesses. The updated policy now offers voluntary...more
12/20/2019
/ Compliance ,
Cooperation ,
Criminal Investigations ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Export Controls ,
Financial Institutions ,
Government Investigations ,
Guidance Update ,
National Security ,
Remediation ,
Terrorism Funding ,
Voluntary Disclosure