News & Analysis as of

Export Controls

Red Notice Newsletter - November 2017

ANTICORRUPTION DEVELOPMENTS – SBM Offshore N.V. Agrees to Pay $238 Million to Resolve DOJ FCPA Enforcement Action - On November 29, 2017, SBM Offshore N.V. (SBM), a Netherlands based company specializing in the...more

Deemed Exports and You

by Tucker Arensberg, P.C. on

You may be surprised to learn that you can commit an export control violation without shipping a single product overseas. This is due to the “deemed export” rule....more

Information filtration under the Export Administration Regulations

by Miller Canfield on

Information provides the cornerstone to the modern economy. Information flows across information technology networks similar to water naturally flowing down our mountains, into our streams and rivers, and out to the oceans....more

US implements key changes to Cuba sanctions financial transactions and travel provisions

by Dentons on

Effective November 9, 2017, the US Department of Treasury’s Office of Foreign Assets Control (OFAC) and the US Department of Commerce’s Bureau of Industry and Security (BIS) amended the Cuban Assets Control Regulations (CACR)...more

U.S. Restrictions on Travel to and Trade With Cuba Return

Effective November 9, 2017, new regulations took effect limiting U.S. travel and trade with Cuba. Decades ago, the United States imposed a commercial embargo on Cuba. The embargo existed in one form or another until 2015,...more

Sudan Now Open For Business, But Risks Remain

On October 12, 2017, the United States made permanent its lifting of a longtime general embargo on trade and investment with Sudan. As a result, U.S. individuals and companies are now generally free to engage in transactions...more

Changes to Cuba Sanctions Program Pursuant to National Security Presidential Memorandum

by Alston & Bird on

On Wednesday, November 8, 2017, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), U.S. Department of State, and U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced...more

Cuba update: Trump tightens travel authorizations and targets new restricted parties

by Hogan Lovells on

On 9 November 2017, the Trump Administration implemented new regulations to support its change to U.S. policy on Cuba. The U.S. Government has created a new Cuba Restricted List administered by the State Department. Through...more

US Implements Changes to Cuba Sanctions

by Dechert LLP on

The U.S. Government this week announced changes to U.S. sanctions against Cuba to implement various policy changes announced by President Trump in July 2017 (for additional background, see our prior OnPoint from June 2017)....more

Masterpiece by Bernardo Bellotto Purchased by London National Gallery Consequent to Temporary Export Bar

Art export laws are designed to prevent art and artifacts of significant cultural value from leaving its country of origin while also preserving the home country’s competitiveness in the international art market. Many...more

BIS Clarifies Use of License Exceptions GOV and STA

On November 1, 2017, the Department of Commerce’s Bureau of Industry and Security (BIS) introduced clarifications to the Export Administrative Regulations (EAR) for the use of license exception “Governments, International...more

MoForward 2018

On Thursday, October 26th, Morrison Foerster’s Government Contracts Group held its inaugural MoForward Event at the Tysons Corner Ritz Carlton. The event was a rousing success, reflecting the unique interaction between our...more

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

Risk Management in the Export Controls Minefield (Part 2 in a Series)

by Blank Rome LLP on

As the recent Bright Lights USA case demonstrates, export violations continue to be met by aggressive enforcement actions by U.S. government authorities. In Bright Lights USA, the U.S. State Department’s Directorate of...more

Not out of the woods yet: What the lifting of Sudan sanctions means for businesses and non-profits

by Hogan Lovells on

Yesterday, on October 12, 2017, the U.S. permanently revoked most sanctions against Sudan. This lifting represents the completion of a process that began in January 2017, and was extended in July 2017. ...more

US lifts most sanctions on Sudan—but key controls and heightened concerns remain

by Dentons on

On October 12, 2017, the United States lifted its general commercial embargo on Sudan, removing sanctions that had prohibited US Persons from engaging in or facilitating most transactions involving Sudan or its government....more

Red Notice Newsletter - Chinese

ANTICORRUPTION DEVELOPMENTS - Alere Inc. Agrees to Pay More Than $13 Million to Resolve SEC FCPA Enforcement Action - On September 28, 2017, Alere Inc. (“Alere”), a Massachusetts based manufacturer of medical diagnostic...more

Red Notice Newsletter - Russian

ANTICORRUPTION DEVELOPMENTS - Alere Inc. Agrees to Pay More Than $13 Million to Resolve SEC FCPA Enforcement Action - On September 28, 2017, Alere Inc. (“Alere”), a Massachusetts based manufacturer of medical diagnostic...more

United States Lifts Sanctions and Ends 20-Year-Old Embargo Against Sudan

by Reed Smith on

Following a 16-month diplomatic effort, on October 6, 2017, the U.S. government announced that it will terminate the vast majority of economic sanctions against Sudan. The revocation, which will be effective on October 12,...more

Red Notice Newsletter - September 2017

ANTICORRUPTION DEVELOPMENTS - Alere Inc. Agrees to Pay More Than $13 Million to Resolve SEC FCPA Enforcement Action - On September 28, 2017, Alere Inc. (“Alere”), a Massachusetts based manufacturer of medical...more

EU and UK Sanctions and Export Controls Update – Autumn 2017

by K&L Gates LLP on

There have been a number of key developments in the European Union (“EU”) and United Kingdom (“UK”) sanctions regimes over the summer of 2017. Alongside the inevitable updates to the UK's sanctions policy in light of Brexit,...more

To Be Cyber Secure – May Not Mean You Are Export Secure

Ensuring that technical data is compliant with both export regulations and cybersecurity requires an understanding of what export controlled technical data/technology relate to and how they work together. The two major export...more

Energy Update - September 2017

by Shearman & Sterling LLP on

We are pleased to release the latest issue of our client newsletter, Energy Update, designed to inform clients and friends of the firm about important developments affecting U.S. and international energy markets. Please...more

Recent ITAR Case Sends Important Message to Small/Midsized Government Contractors

by Williams Mullen on

A State Department ITAR enforcement case announced last week involving a supplier of military spare parts sends a valuable message to small and mid-sized government contractors of every type. The case involves Bright Lights...more

Risky Business: Mitigating Exposure Through Comprehensive Risk Management

by Ropes & Gray LLP on

Ropes & Gray is pleased to share “Risky Business,” a comprehensive report on trends and best practices in risk management. Based on a survey by FT Remark, a research service from the Financial Times that interviewed 300...more

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