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Corporate Counsel Export Controls

Morrison & Foerster LLP

OFAC Extends Recordkeeping Requirements from Five to 10 Years; Issues Paperwork Reduction Act Request for Comments

On September 11, 2024, OFAC announced its Interim Final Rule to Extend Recordkeeping Requirements from Five to 10 Years. The Interim Final Rule (IFR) was published in the Federal Register on September 13, 2024. Public...more

Dorsey & Whitney LLP

Biden Administration Again Expands Sanctions on Russia and Its Third Party Supporters

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As Russia continues its war against Ukraine and Ukraine has itself recently opened a new front by capturing Russian territory in its Kursk region, the United States announced on August 23 its latest tranche of sanctions...more

The Volkov Law Group

RTX Corporation Reaches Record $200 Million Settlement with DDTC for Serial Violations of the AECA and ITAR

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On August 30, 2024, the U.S. Department of State’s Directorate of Defense Trade Controls (“DDTC”) announced the settlement of a record $200 million administrative enforcement action with RTX Corporation—a multinational...more

Blank Rome LLP

DDTC Issues Long-Awaited Rule Implementing AUKUS: Five Key Takeaways

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On August 16, 2024, the U.S. Department of State (“State”) announced a broad exemption from export licensing requirements for most defense trade between and among “authorized users” in the United States, Australia, and the...more

Skadden, Arps, Slate, Meagher & Flom LLP

EU’s 14th Sanctions Package: Compliance Obligations Expand and Exits Are Facilitated

On 24 June 2024, the European Union (EU) adopted its 14th sanctions package directed against Russia, imposing an asset freeze against an additional 116 individuals and entities and expanding sectoral sanctions targeting key...more

Fenwick & West LLP

U.S. Government Removes Export Control Barriers for U.S. Companies Participating in Standards-Setting Bodies

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The U.S. government’s primary export control regulator – the Bureau of Industry and Security (BIS) within the Commerce Department – issued a new rulemaking to remove barriers from U.S. companies’ participation in...more

Pillsbury - Global Trade & Sanctions Law

EU’s 14th Package of Sanctions on Russia

On 24 June 2024, the EU adopted its 14th package of sanctions against Russia. The latest measures include: The designation of 116 additional individuals and entities across a number of industries for their responsibility in...more

Akin Gump Strauss Hauer & Feld LLP

DOJ Announces First-Ever Corporate Declination Under National Security Division’s Voluntary Self-Disclosure Program

Key Points - On May 21, 2024, the DOJ announced its first ever declination under the NSD’s updated Enforcement Policy, declining to prosecute Sigma-Aldrich Inc., d/b/a MilliporeSigma (a subsidiary of Merck KGaA, Darmstadt,...more

Morrison & Foerster LLP

China Strengthens Protection of State Secrets as Revised Law Takes Effect

China’s amended Law on Guarding State Secrets (“SSL”) took effect on May 1, 2024. This amendment is part of a broader legislative push to enhance national security and data protection, aligning with other recent laws such as...more

Morrison & Foerster LLP

OFAC Issues Omnibus Accounts Enforcement Case Involving Russia and Other Sanctions Programs

On March 14, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced its first enforcement case of the year and its first ever involving dealings with a Russian designated for sanctions...more

Cooley LLP

UK Introduces Export Controls for Emerging Technologies

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On 12 March 2024, the UK Export Control Joint Unit (ECJU) announced that UK export control regulations would be amended to introduce new controls on the export of emerging technologies and provide a number of technical...more

The Volkov Law Group

Boeing Reaches $51 Million Settlement with State Department for ITAR Violations

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Boeing continues to struggle. As troubles mount for Boeing, it  is clear that it suffers from real and pervasive culture issues that have been reflected in serious safety failures, financial difficulties, regulatory...more

A&O Shearman

U.S. Imposes New Russia Sanctions and Export Controls and Warns of Risk of Continued Business with Russia

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On February 23, 2024, the United States imposed its largest number of new sanctions and export control designations against Russia to date—targeting over 600 individuals and entities across a wide swath of the Russian economy...more

Mayer Brown

UK Government to launch new unit to enforce export controls and trade sanctions

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On 11 December 2023, the UK Government announced plans to create the Office of Trade Sanctions Implementation (OTSI), a new governmental body that will be responsible for inter alia the civil enforcement of UK trade...more

Oberheiden P.C.

Insights from OFAC Enforcement Actions So Far

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Each year, the Office of Foreign Assets Control (OFAC) initiates several enforcement actions targeting companies, financial institutions, and individuals in the United States and abroad. These enforcement actions can present...more

Fenwick & West LLP

New Official Guidance on Voluntary Self-Disclosure of Trade Control Violations

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On July 26, 2023, the U.S. Department of Commerce, Bureau of Industry and Security (BIS), the U.S. Department of the Treasury Office of Foreign Asset Control (OFAC) and the U.S. Department of Justice (DOJ) released joint...more

Vinson & Elkins LLP

S.D.N.Y. Awards Aircraft Owner Over $406 Million for Aircraft and Engines Trapped in Russia

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U.S. companies that found their assets caught up in Russia at the start of the Russia/Ukraine conflict may find relief on paper from U.S. courts. But it remains to be seen whether they can recover in practice....more

Fenwick & West LLP

U.S. Government Imposes New Export Controls and Sanctions on Russia and Belarus

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On May 19, 2023, the Biden administration announced another major round of U.S. sanctions and export controls against Russia and Belarus in response to the ongoing war in Ukraine, in coordination with the G7 Leaders’ Summit...more

A&O Shearman

Russian Countersanctions: New Measures Targeting Foreign Investors in Russia

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Fourteen months into the Ukraine war, the Russian Government has introduced new countersanctions targeting foreign investors in Russia. The latest measures require businesses from “unfriendly” countries to make a “voluntary...more

Dechert LLP

A New Risk Calculus: U.S. Department of Commerce Raises Stakes for Failing to Voluntarily Self-Disclose Potential Export Controls...

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On April 18, 2023, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) Assistant Secretary for Export Enforcement, Matthew Axelrod, published a memorandum marking a shift in policy regarding voluntary...more

The Volkov Law Group

Bureau of Industry and Security Extracts $300 Million Fine Against Seagate Technology for Violation of Huawei Prohibition

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Matt Axelrod, the Assistant Secretary for Export Enforcement, at the Bureau of Industry and Security (“BIS”) of the U.S. Department of Commerce, must be grinning with satisfaction that BIS delivered, in a big way, after he...more

Orrick, Herrington & Sutcliffe LLP

Three Signs of a New Era in U.S. Export Controls and Sanctions Enforcement

In light of Russia’s invasion of Ukraine and intensifying strategic competition with China, the U.S. government is prioritizing enforcement of export controls and economic sanctions in unprecedented ways. We expect higher...more

Holland & Knight LLP

International Trade Compliance Year in Review: 10 Enforcement Lessons from 2022

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In the past year, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC), the U.S. Department of Commerce's Bureau of Industry and Security (BIS) and the U.S. Department of State's Directorate of...more

Skadden, Arps, Slate, Meagher & Flom LLP

Latest EU Russian Sanctions Expand Sector Restrictions and Add Designated Individuals and Entities

On 16 December 2022, the European Union (EU) adopted a ninth package of sanctions against Russia. These impose an asset freeze on almost 200 additional individuals and entities pursuant to Council Regulation No. 269/20141...more

Porter Hedges LLP

Update on Russian-Related Sanctions and Export Controls

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As the Russian invasion of Ukraine continues, the executive branch is mounting what the U.S. Department of Treasury (“Treasury”) calls a “historically unprecedented campaign of sanctions and export controls” aimed at...more

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