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Due Diligence Export Controls Office of Foreign Assets Control (OFAC)

BakerHostetler

Key Export Control Developments During the First Quarter of 2024

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The first quarter of 2024 saw numerous developments on the export control front. This report summarizes the key developments and provides links to the relevant Federal Register notices and/or agency announcements....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

Snell & Wilmer

United States Announces Largest Round of Sanctions Since the Start of Russia’s War in Ukraine

Snell & Wilmer on

The U.S. Government recently announced the largest round of sanctions against the Russian Federation (Russia) since the invasion of Ukraine two years ago. This multi-agency effort enacted over 500 sanctions against foreign...more

American Conference Institute (ACI)

Sanctions Compliance Measures to Mitigate Russia Trade Sanctions Evasion Tactics

The various and elusive tactics used by Russia to evade global sanctions and export controls have grown increasingly sophisticated over the last several months, putting the onus on multinational entities to become equally...more

Seward & Kissel LLP

The Importance of Sanctions and Export Control Compliance

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The United States manages more than three dozen separate economic and trade sanctions programs. Those programs target specified foreign governments along with thousands of named individuals, groups and entities in accordance...more

K2 Integrity

Sanctions Against Russia: U.S. Introduces New Russia-Related Sanctions Targeting Foreign Financial Institutions And Tightens Other...

K2 Integrity on

On 22 December 2023, the Biden administration issued Executive Order 14114, “Taking Additional Steps with Respect to the Russian Federation’s Harmful Activities” (EO 14114), thereby amending EOs 14024 and 14068. The new EO...more

Husch Blackwell LLP

BIS Implements Additional Export Controls and Entity List Additions Targeting Russia to Align with Allies and Partners

Husch Blackwell LLP on

On May 19, 2023, the Department of Commerce’s Bureau of Industry and Security (“BIS”) announced new export controls and Entity List additions during President Biden’s G7 visit in Japan. In conjunction with the G7 meetings,...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

Seward & Kissel LLP

Importance of Timely Sanctions Screening and Due Diligence

Seward & Kissel LLP on

The United States sanctions regime is a complex and ever-changing regulatory space. The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) maintains sanctions lists which are updated in real-time—not on...more

American Conference Institute (ACI)

[Event] Canadian Forum on Global Economic Sanctions - September 22nd - 23rd, Toronto, ON, Canada

The Canadian Institute’s 7th Annual Canadian Forum on Global Economic Sanctions returns to Toronto in-person and via livestream on September 22-23! Join a Canadian and international faculty of government of officials,...more

Holland & Knight LLP

Navigating Russian Sanctions in Corporate Jet Transactions

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The U.S., European Union (EU), United Kingdom (U.K.) and many other countries have imposed similar but not necessarily identical sanctions on Russia. In corporate jet transactions, the sanctions laws of several jurisdictions...more

K2 Integrity

Sanctions Against Russia: Understanding the Evolving Picture and How to Respond

K2 Integrity on

...Since the start of the invasion of Ukraine by Russian forces on February 24, the United States (U.S.), United Kingdom (UK), and the European Union (EU) have led a global sanctions campaign against Russia that has been...more

American Conference Institute (ACI)

[Virtual Conference] Navigating Russia Sanctions Complexities - September 27th, 10:00 am - 5:00 pm EDT

Unravel the multiple layers of primary and secondary Russia Sanctions and strengthen your analytical decision-making process. The Russia sanctions landscape continues to evolve in many significant ways. ACI’s 4th...more

WilmerHale

OFAC Enforcement Actions Highlight Risks to Software Providers & MSBs

WilmerHale on

On April 29, 2021, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced two settlements of potential civil liability with two companies over their apparent violations of its regulations. The...more

Society of Corporate Compliance and Ethics...

[Virtual Event] 2021 Middle East and Africa Regional Compliance & Ethics Conference - February 11th, 8:55 am - 2:00 pm GST

Our Virtual Regional Compliance Conferences provide updates on the latest news in regulatory requirements, compliance enforcement, and strategies to develop effective compliance programs. Watch, listen, and ask questions from...more

Foley & Lardner LLP

Recent Government Announcements Confirm Importance of International Regulatory Compliance for Automotive Companies

Foley & Lardner LLP on

Over the last three years, the current administration has imposed the largest export controls penalty, the second-largest economic sanctions penalty, and four of the ten largest anti-bribery penalties of all time, signaling...more

American Conference Institute (ACI)

[Event] 5th Asia Pacific Summit on Economic Sanctions Compliance and Enforcement – October 15th, Singapore

Recent investigations targeting companies in various industry sectors ranging from technology to finance, and shipping to insurance, illustrate that economic sanctions are a high risk area for companies in Asia. Our Asia...more

Bass, Berry & Sims PLC

OFAC Settles with Cosmetics Company, Reiterates Importance of Supply Chain Compliance

• Company committed multiple apparent violations of U.S. sanctions on North Korea • Penalty imposed in part because of company’s “non-existent” sanctions compliance program • Settlement underscores need to address supply...more

King & Spalding

e.l.f. Cosmetics Agrees to Pay Nearly $1 Million To Settle Apparent Violations Of U.S. Sanctions Against North Korea

King & Spalding on

This Enforcement Action Underscores The Risks Of Sourcing Products Without Comprehensive Supply Chain Due Diligence - On January 31, 2019, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of the Treasury...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - October 2017

ANTICORRUPTION DEVELOPMENTS – Global Compliance Overhaul for SAP as DOJ and SEC Investigate Payments Allegedly Related to South African Government Contracts – On October 26, 2017, German software company SAP SE...more

Perkins Coie

Court Opinion on Liability for Re-Exports to Iran Spurs Practical Guidance for U.S. Exporters

Perkins Coie on

A recent federal appeals court decision addresses a familiar issue for many companies: When can a U.S. exporter be liable for a product that is re-exported to a sanctioned country, such as Iran? This update summarizes the...more

Foley & Lardner LLP

Private Equity and the New Trump Administration: Your Top Ten Questions Answered

Foley & Lardner LLP on

The election of President Trump contained more than a few positive signs for Private Equity (PE) firms. Promises of a lower corporate tax environment, a ten-percent tax holiday for funds parked overseas, large infrastructure...more

Williams Mullen

“Reason To Know” – A Chilling Term For Exporters

Williams Mullen on

It’s a simple question – if a U.S. exporter sells its product to a foreign customer, and the customer resells the product to a prohibited country such as Iran, can the U.S. exporter have liability for an export violation? ...more

Kelley Drye & Warren LLP

Epsilon Case Highlights the Need for Sanctions Due Diligence on Resellers

As global companies begin to reenter the Iranian market, a decision issued by the U.S. District Court for the District of Columbia is an important reminder that resellers and distributors can generate liability for U.S....more

Williams Mullen

Export Control Laws for the General Counsel

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You are the chief legal officer of a U.S. company. Your CEO walks into your office and announces that your company is about to conclude its first international sale. In addition, the company has just appointed distributors in...more

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