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Statute of Limitations for IEEPA and TWEA Violations Extended to 10 Years, and Additional Sanctions Developments

Recent legislation, H.R. 815, the National Security Supplemental (“the Act”) – further explained by guidance issued by the U.S. Department of the Treasury Office of Foreign Assets Control (“OFAC”) on July 22, 2024 – has...more

DOJ OFAC BIS Joint Compliance Note and Enhanced Coordination Highlights Increased Enforcement Risk

On July 26, 2023, the U.S. Departments of Justice, Treasury, and Commerce issued a joint compliance note (“JCN”) regarding voluntary self-disclosure (“VSD”) policies that apply to potential violations of U.S. sanctions...more

New Emphasis on Human Rights and Human Rights Due Diligence in U.S. Export Controls

As the European Union has made continued progress toward implementing a holistic human rights legislative agenda, the United States, in the wake of the recent second Summit for Democracy, began to push its own set of human...more

New U.S. Semiconductor Technology Controls Impose Strict Burdens, and Sow Confusion

On October 7, 2022, the Commerce Department Bureau of Industry and Security (“BIS”) – the primary gatekeeper on U.S. export controls – unleashed two lengthy and highly complex sets of regulations, aimed squarely at stopping...more

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