During the first quarter of 2024, there were significant developments in the U.S. sanctions framework. This report summarizes the key developments and provides links to the relevant sources....more
The Bureau of Industry and Security (BIS) of the U.S. Department of Commerce announced this past week that it was adding more than three dozen companies to the Entity List effective immediately. This is the second round of...more
After months of negotiations, Congress revealed the compromise version of the National Defense Authorization Act for Fiscal Year 2023 (NDAA) on December 6, 2022. The bill, viewed as a “must-pass” piece of legislation because...more
This is the fifth post in this year’s series examining important trends in white collar law and investigations. Our previous post discussed trends in State AG enforcement. Up next: SEC Enforcement in 2022: A Look Ahead. ...more
On January 26, 2022, the U.S. Department of the Treasury issued an advisory for businesses and individuals doing business in Burma. Specifically, the business advisory cautions business and individuals to be aware of exposure...more
1. Treasury Mandates Reporting of Foreign Securities Holdings of $200M or More- All U.S. persons (custodians and end investors) who manage $200 million or more in foreign securities for themselves or others must file a...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
Effective June 1, 2021, the U.S. Department of the Treasury's Office of Foreign Assets Control (“OFAC”) published new Burmese Sanctions Regulations (“BSR”) that implement President Biden’s February 10, 2021, Executive Order...more
U.S., UK and EU authorities continue to expand sanctions targeting the Tatmadaw, Myanmar’s armed forces, following the February 17, 2021, military coup in Myanmar (also known as Burma). Over the past month, the United States...more
Recently, on April 9, 2021, the US Commerce Department’s Bureau of Industry and Security (BIS) adopted new restrictions targeting Burma by applying Export Administration Regulations’(EAR’s) military-intelligence end-use and...more
On March 25, 2021, the United States imposed sanctions on Myanma Economic Holdings Public Company Limited ("MEHL") and Myanmar Economic Corporation Limited ("MEC"), Burma's two largest military conglomerates. On the same day,...more
There’s been a non-stop bombardment of recent export amendments involving China and other “countries of concern” within the last six months. The main driver behind these has been the U.S. Government’s concern about the...more
On 4 March 2021, the Department of Commerce's Bureau of Industry and Security (BIS) announced that it would impose additional export controls measures on Burma, adding to measures already taken by the Biden administration in...more
U.S. officials have continued to use a range of policy tools to apply pressure on the military leadership of Myanmar (also known as Burma) in response to the military coup in the country and escalating violence against...more
On February 1, 2021, the Burmese military announced that it had seized control of the country from the country's democratically elected government.1 In response to the coup, the US has so far designated 12 individuals and...more
Key Points - On February 11, 2021, in the first deployment of sanctions since assuming office, President Biden issued EO 14014, authorizing sanctions against members of the Burmese military and related parties responsible...more
In response to the February 1, 2021, military coup in Burma (Myanmar), on February 10, 2021, President Joe Biden issued Executive Order 14014 (EO 14014), “Executive Order on Blocking Property With Respect to the Situation in...more
On February 11, 2021, the Biden Administration created a new sanctions regime and imposed additional export restrictions in response to the recent military coup in Burma. While the new measures do not broadly prohibit doing...more
In response to the recent military coup in Myanmar (also known as Burma) against the democratically-elected government, on February 11, 2021 the Biden Administration issued an Executive Order on Blocking Property with Respect...more
On Friday, October 7, 2016, President Obama delivered on a promise that he had made in September by signing an executive order terminating the economic and financial sanctions program on the country of Burma (Myanmar). The...more
On September 14, 2016, the President announced his intention to terminate the national emergency with respect to Burma, the effect of which will be to end the current U.S. sanctions program against that country as overseen by...more
On June 8, attorneys for the U.S. Department of Justice (DOJ) joined Dutch aerospace company Fokker Services BV (“Fokker”) in appealing the district court’s rejection of Fokker’s deferred prosecution agreement (DPA) with the...more