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Tri-Seal Compliance Note Issued on Export Controls, Sanctions Violations Self-Disclosures

The U.S. Department of Justice (DOJ), Department of Commerce's Bureau of Industry and Security (BIS) and Department of the Treasury's Office of Foreign Assets Control (OFAC) on July 26, 2023, issued a Tri-Seal Compliance Note...more

United States Imposes Expanded Sanctions and Export Controls on Russia

The U.S. Department of Commerce's Bureau of Industry and Security (BIS) took a number of actions under the Export Administration Regulations (EAR) on May 19, 2023. Here are some of the key U.S. export control actions...more

OFAC Updates U.S. Oil Price Cap Policy Against Russia

As an update to an earlier Holland & Knight alert on the same topic, the U.S. Department of the Treasury Office of Foreign Asset Control (OFAC) has published another determination pursuant to Executive Order 14071 expanding...more

OFAC Places Price Cap on Maritime Services Related to Russian Oil

The U.S. Department of the Treasury Office of Foreign Asset Control (OFAC) on Nov. 21, 2022, published a determination pursuant to E.O. 14071 prohibiting U.S. persons from providing certain services related to the maritime...more

OFAC Provides Relief for Certain Aviation and Maritime Vessels

The U.S. Department of the Treasury's Office of Foreign Asset Control (OFAC) recently issued two general licenses related to aviation and maritime safety. OFAC issued Russia-related General License 40C (GL 40C), Civil...more

Input Sought on Licensing Mechanism for ICTS Transactions Involving "Foreign Adversaries"

The U.S. Department of Commerce (Commerce) recently announced its "apparent" need for public comment on key aspects of a mechanism that would license or preclear certain information and communications technology and services...more

ICTS Investigations: The Commerce Department's New Tool

Back in May 2019, the Trump Administration issued Executive Order 13873, which was meant to police the use of certain information and communications technology and services (ICTS) purchased from "foreign adversaries." Then,...more

Securing the U.S. Power Grid: President and Commerce Department Sound the Alarm

President Donald Trump signed Executive Order 139201 on May 1, 2020, declaring a national emergency in order to secure the nation's bulk-power system. The president's order explains that such systems are threatened by foreign...more

Trump Administration Establishes New Sanctions Regime Targeting Human Rights Abusers - Also Expands Existing Sanctions on...

The Trump Administration rounded out the year with two sanctions-related actions: The first involved creating a new program regarding human rights abusers and global corruption; the second involved adding several individuals...more

U.S. Government Issues Guidance on Expanded Russia Sanctions

• The U.S. Department of State issued public guidance on sanctions with respect to 39 named entities related to Russia's defense and intelligence sectors. This guidance is issued under Section 231 of the Countering America's...more

ExxonMobil Fined $2 Million for Ukraine/Russia Sanctions Violations

On July 20, 2017, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) announced a $2 million civil monetary penalty against Exxon Mobil Corp., including its U.S. subsidiaries ExxonMobil Development...more

Obama Uses Executive Order Authority to Respond to Malicious Russian Cyber Activity - President Amends EO 13964 From April 2015 in...

President Barack Obama amended Executive Order (EO) 13964 on December 29, 2016, in response to intelligence community findings that the Russian government engaged in malicious cyber activity with respect to the U.S. electoral...more

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