October saw two major enforcement actions involving Russia. First, three individuals were indicted for facilitating the export of controlled U.S.-origin electronics to Russia. Second, the president of a U.S. steel trading...more
11/9/2023
/ Bureau of Industry and Security (BIS) ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Exports ,
General Licenses ,
International Emergency Economic Powers Act (IEEPA) ,
Iran ,
Office of Foreign Assets Control (OFAC) ,
Regulatory Agenda ,
Regulatory Requirements ,
Russia ,
Semiconductors ,
Technology Sector ,
U.S. Commerce Department ,
U.S. Treasury ,
Venezuela
July saw two noteworthy Russia enforcement actions. A Russian national was arrested in Estonia and extradited to the United States after being charged with conspiring to procure U.S.-origin technologies and ammunition on...more
8/17/2023
/ Antiboycott Requirements ,
China ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Exports ,
Foreign Entities ,
Foreign Nationals ,
General Licenses ,
Iran ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanction Violations ,
U.S. Commerce Department ,
U.S. Treasury ,
Ukraine
The Bass, Berry & Sims international trade team continues to monitor U.S. government action in response to Russia’s invasion of Ukraine. In the final months of 2022, the U.S. government added multiple individuals and entities...more
The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and...more
10/4/2022
/ Aircraft ,
Blocked Person ,
Bureau of Industry and Security (BIS) ,
Defense Sector ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Final Rules ,
General Licenses ,
Intelligence Services ,
Iran ,
Military End Use ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Technology Sector ,
U.S. Treasury ,
Ukraine
The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and...more
The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and...more
7/8/2022
/ Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Financial Transactions ,
FinCEN ,
General Licenses ,
Gold ,
Imports ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Trade Restrictions ,
Ukraine
The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and...more
6/2/2022
/ Aviation Industry ,
Blocked Person ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
General Licenses ,
Russia ,
Sanction Violations ,
SDN List ,
Travel Restrictions ,
Ukraine
The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and...more
The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and...more
5/6/2022
/ Aircraft ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Prohibited Transactions ,
Russia ,
U.S. Commerce Department ,
Ukraine
The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and...more
The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and...more
4/12/2022
/ Belarus Sanctions ,
Biden Administration ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Direct Product Rule ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Ukraine
The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and...more
4/6/2022
/ Belarus Sanctions ,
Biden Administration ,
Economic Sanctions ,
Executive Orders ,
Export Controls ,
Foreign Trade Regulations ,
General Licenses ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Ukraine
The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes the evolving situation as of...more
The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes the evolving situation as of...more
3/15/2022
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Financial Institutions ,
Foreign Investment ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Ukraine
This UPDATED post summarizes the situation as of late evening on Monday, March 7, concerning current U.S. sanctions and export restrictions related to Russia and Ukraine...more
3/8/2022
/ Belarus ,
Economic Sanctions ,
Export Controls ,
Foreign Direct Investment ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
South Korea ,
U.S. Commerce Department ,
Ukraine
This UPDATED post summarizes the situation as of late evening on Thursday, March 3, concerning current U.S. sanctions and export restrictions related to Russia and Ukraine...more
3/4/2022
/ Asset Freeze ,
Belarus Sanctions ,
Departments of Commerce ,
Economic Sanctions ,
Entity List ,
Export Controls ,
Final Rules ,
Foreign Direct Investment ,
Foreign Relations ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Ukraine
• Actions underscore long arm of U.S. sanctions jurisdiction
• Voluntary disclosures and cooperation can lead to significant penalty reductions
• Facilitation of a violation is treated the same as a direct...more
3/5/2020
/ Civil Liability ,
Civil Monetary Penalty ,
Cooperation ,
Economic Sanctions ,
Enforcement Actions ,
General Licenses ,
Global Terrorism Sanctions Regulations (GTSR) ,
Jurisdiction ,
Myanmar ,
Office of Foreign Assets Control (OFAC) ,
Sanction Violations ,
SDN List ,
Shipping ,
Telecommunications ,
Voluntary Disclosure
• Virtually all transactions with government prohibited
• Most transactions with private sector parties still permitted
• Practical challenges make Venezuela transactions difficult, including for non-U.S. parties
On...more
• Economic sanctions and export restrictions extended
• Russian investment in United States likely subject to heightened scrutiny
• Diligence on Russia transactions and business partners is essential to ensure...more
9/27/2018
/ CAATSA ,
CBW Act ,
CFIUS ,
Defense Sector ,
Economic Sanctions ,
Executive Orders ,
Export Controls ,
Exports ,
FIRRMA ,
Foreign Investment ,
Foreign Policy ,
General Licenses ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Trade Restrictions ,
Trump Administration ,
U.S. Treasury
• Previously permissible activities must be wound down in 90 or 180 days
• Non-U.S. companies at particular risk of enforcement action
• Only limited guidance issued so far, unclear what authority U.S. companies...more
- Virtually all U.S. sanctions on Sudan lifted effective January 17, 2017
- Sanctions could be permanently lifted in six months
- There continue to be practical challenges to doing business in Sudan...more
1/19/2017
/ Barack Obama ,
Economic Sanctions ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Exports ,
General Licenses ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
Revocation ,
State Sponsors of Terrorism ,
Sudan
Effective December 23, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) amended the Iranian Transactions and Sanctions Regulations (ITSR) to expand the scope of medical devices that can be exported to...more
With the results in from the U.S. presidential election, companies should begin to consider the potential impact of a Trump presidency on their international business. U.S. economic sanctions were among the hot-button issues...more
11/22/2016
/ Barack Obama ,
Cuba ,
Economic Sanctions ,
Executive Orders ,
Federal Contractors ,
General Licenses ,
Iran ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
Repeal ,
Russia ,
Trump Administration
Over the past year, the big news for companies doing or considering business in Iran has been the scaling back of U.S. and EU economic sanctions. Many global businesses are now permitted to operate in this once prohibited...more
11/2/2016
/ Certification Requirements ,
Economic Sanctions ,
False Claims Act (FCA) ,
Federal Acquisition Regulations (FAR) ,
General Licenses ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
System For Award Management (SAM)