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
7/25/2024
/ Cybersecurity ,
Economic Sanctions ,
Enforcement ,
EU ,
Export Controls ,
International Emergency Economic Powers Act (IEEPA) ,
Iran ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Statute of Limitations ,
Trading with the Enemy Act ,
U.S. Treasury ,
UK ,
US Department of State
Broad authorizations permitting dealings in Venezuela’s oil and gas sector came to an end on April 17, 2024, when the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) terminated General...more
On February 23, 2024, the Biden Administration announced new sanctions targeting a number of different sectors of the Russian economy, Russian government officials and financial institutions, entities suspected of sanctions...more
3/11/2024
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
PRC ,
Russia ,
SDN List ,
U.S. Treasury ,
US Department of State
On October 18, 2023 the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a set of new authorizations under the Venezuela sanctions regime, including a temporary suspension of...more
Russia’s invasion of Ukraine has resulted in the United States, European Union, United Kingdom and numerous other jurisdictions implementing the most draconian economic sanctions ever imposed on a major economy. While those...more
On October 4, 2023, Deputy Attorney General Lisa Monaco (the “DAG”) announced a new Mergers & Acquisitions (“M&A”) Safe Harbor Policy issued by the Department of Justice (“DOJ”) as part of her comments detailing increased...more
10/10/2023
/ Anti-Corruption ,
Antitrust Division ,
Compliance ,
Corporate Governance ,
Corporate Misconduct ,
Criminal Mischief ,
Department of Justice (DOJ) ,
Due Diligence ,
Enforcement Actions ,
Federal Trade Commission (FTC) ,
Foreign Corrupt Practices Act (FCPA) ,
Mergers ,
National Security ,
Safe Harbors ,
Voluntary Disclosure
On September 26, 2023, the “Export Enforcement Five” or “E5” partnership among the governments of Australia, Canada, New Zealand, the United Kingdom, and the United States issued joint guidance focused on preventing Russian...more
10/4/2023
/ Bureau of Industry and Security (BIS) ,
Compliance ,
Due Diligence ,
Economic Sanctions ,
End-Users ,
Evasion ,
Exporters ,
Financial Institutions ,
Globally Harmonized System ,
Priority Watch Lists ,
Red Flags Rule ,
Russia ,
Technology Sector
On August 9, 2023, President Biden issued a long-awaited Executive Order establishing the legal authority for the U.S. Department of Treasury (“Treasury Department”) to institute an unprecedented regulatory regime restricting...more
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
8/4/2023
/ Bureau of Industry and Security (BIS) ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
FinCEN ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
U.S. Commerce Department ,
U.S. Treasury ,
Whistleblowers
On 17 October 2022, the respective directors of the United Kingdom’s Office of Financial Sanctions Implementation (“OFSI”) and the United States’ Department of the Treasury Office of Foreign Assets Control (“OFAC”), Giles...more
Business and human rights is continuing its steady march toward becoming a business imperative. There are sweeping new or proposed laws focused on human rights, such as the EU’s Proposal for a Directive on Corporate...more
6/9/2022
/ Code of Conduct ,
Customs and Border Protection ,
Economic Sanctions ,
Employee Privacy Rights ,
EU ,
Export Controls ,
Forced Labor ,
Free Trade Agreements ,
General Data Protection Regulation (GDPR) ,
Human Rights ,
Modern Slavery Act ,
NLRB ,
Popular ,
Public Procurement Policies ,
Supply Chain ,
Sustainability ,
UK ,
United States-Mexico-Canada Agreement (USMCA) ,
Uyghur Forced Labor Prevention Act (UFLPA)