In the last few years, changes to the United States enforcement stance on the forced labor import ban authorized by 19 U.S.C. § 1307 and passage of the Uyghur Forced Labor Prevention Act (UFLPA) have fundamentally changed the...more
Did you know that whistleblowers can use the False Claims Act to get the U.S. Government to investigate allegations of lost revenue to the U.S. Treasury, including underpaid Customs tariffs? A large importer recently found...more
On August 8, 2023, the Department of the Treasury's Office of Foreign Assets Control (OFAC) issued General License 13F Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024...more
The U.S. continues to spearhead enforcement against imported goods that were made using forced labor, and public enforcement statistics can help your company assess risks of forced labor. Under the Uyghur Forced Labor...more
U.S. Customs and Border Protection (CBP) held The Forced Labor Technical Expo: Tools for Supply Chain Transparency from March 14-15, 2023, which involved members of the U.S. importing community, partner government agencies,...more
This update addresses the full implementation of the price cap policy for crude oil and petroleum products of Russian origin by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). On Feb. 3, OFAC...more
On January 5, 2023, President Biden signed into law S. 1294, the “Protecting American Intellectual Property Act of 2022”. The Act requires the president to report to Congress and impose sanctions on any foreign person or...more
In response to the Russian Federation’s (Russia) egregious and unprovoked invasion of Ukraine that began in February 2022, the U.S. government has deployed a whole-of-government approach in imposing sanctions and export...more
The Uyghur Forced Labor Prevention Act (“UFLPA” or “Act”), which took effect last month, ushers in a new era of supply chain diligence for importers. The Act creates a rebuttable presumption that any goods produced in whole...more
On June 13, 2022, U.S. Customs and Border Protection (“CBP”) published its long-awaited operational guidance (“Guidance”) to importers to explain how CBP plans to implement the Uyghur Forced Labor Prevent Act (“UFLPA”) that...more
Ensuring compliance is key for an organization’s success. The ongoing conflict in Ukraine is a salient reminder that the world shifts on its axis from time to time, and many of our working assumptions have to go by the...more
On May 13, 2022, the U.S. Treasury (“Treasury”) released its 2022 Strategy for Combatting Terrorist and Other Illicit Financing (“2022 Strategy”). The proposed 2022 Strategy, prepared pursuant to Sections 261 and 262 of the...more
Now that the United States and its allies have deployed many of their available financial and trade weapons in support of Ukraine against Russia's invasion, what happens next? Perhaps more than any other U.S. sanctions...more
The United States, Russia, the North Atlantic Treaty Organization (“NATO”) and the Organization for Security and Co-operation in Europe (“OSCE”) held a series of talks this week aimed at de-escalating the situation at the...more
On Thursday, December 23, 2021, President Biden signed the Uyghur Forced Labor Prevention Act (the “Act”) into law. The Act aims to “ensure that goods made with forced labor in the Xinjiang Uyghur Autonomous Region of the...more
In the latest turn of events in the seemingly never-ending political saga of the Nord Stream 2 pipeline, the U.S. House of Representatives (the “House”), via an amendment to the 2022 National Defense Authorization Act...more
In response to a variety of activities allegedly undertaken by Russia, the U.S. Government has imposed a series of additional sanctions and export control measures since early March. Collectively, the March and April...more
In March 2021, three federal agencies promulgated international trade restraints as part of the Biden Administration’s response to alleged mistreatment of Russian opposition leader Alexey Navalny in 2020. Specifically, the...more
The still evolving US sanctions (as well as the EU and now also separate UK sanctions) continue to challenge Russia-related business. The sanctions frameworks are complex, changing, and, at times, inconsistent as well as...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 2 March 2021, the United States and European Union ("EU") imposed coordinated sanctions in response to the poisoning and imprisonment of Russian opposition politician Aleksey Navalny (and the related US determination that...more
Recent sanctions imposed by the European Union, United Kingdom, and the United States on Turkey and certain Turkish persons will be of interest to European and American investors in Turkey’s defense and energy sectors. The...more
Turning to the business of exports from the United States, the next section is a must-read for any company doing business in the United States or from the United States. Or for that matter, any company competing with affected...more
Key Points - On December 14, 2020, in response to Turkey’s procurement of the S-400 surface-to-air missile system from Russia in 2019, the Trump administration imposed new sanctions on the Turkish Presidency of Defense...more
On December 14, 2020, the United States (US) imposed sanctions on Turkey pursuant to Countering America’s Adversaries Through Sanctions Act (CAATSA) for “knowingly engaging in a significant transaction with Rosoboronexport...more