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Export Controls Anti-Corruption Office of Foreign Assets Control (OFAC)

Foley & Lardner LLP

The Non-Compliant Cat in the Hat

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So, just before Easter, in 1957, a little book you may have heard of, called The Cat in the Hat, made its first appearance. Theodore Geisel — writing under the name “Dr. Suess” — later said that of all his children’s books,...more

Jenner & Block

Client Alert: Post-Conflict Reconstruction: Opportunities and Risks

Jenner & Block on

After years of destabilizing international and non-international armed conflict that has resulted in the loss of lives, destruction of communities, and decimation of economic opportunity in places across the globe, there are...more

The Volkov Law Group

The Sanctions Year in Review: DOJ takes First Steps to Enforce “The New FCPA” While OFAC’s Enforcement Actions Decline

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Enforcement and compliance prognosticators (like myself) continued to push DOJ’s promise to transform sanctions enforcement into the era of “the new FCPA.” While DOJ’s promise to bring about an aggressive corporate...more

American Conference Institute (ACI)

FCPA, Export Controls, and Sanctions Enforcement: Adjusting Compliance Strategies for the New Normal

As the interplay between export controls, trade sanctions, and anticorruption enforcement continues to intensify, multinational companies must remain vigilant in ensuring that their compliance programs address the many...more

The Volkov Law Group

The Four Sanctions Compliance Cases that Everyone Should Know (Part I of IV)

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The Justice Department has repeated on several occasions that it intends to aggressively prosecute corporations for sanctions and export controls violations. The “New FCPA” is how the Justice Department characterizes its...more

The Volkov Law Group

OFAC Releases Guidance on Extended Statute of Limitations & Forthcoming Recordkeeping Changes

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The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) has released updated guidance concerning recent legislation that doubled the statute of limitations for violations of certain sanctions and export control...more

The Volkov Law Group

Episode 328 -- Sanctions Enforcement Risks and Redlines

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In this new era of aggressive sanctions enforcement, companies have to understand the red lines that define where criminal and civil enforcement risk increase. In contrast to the history of FCPA enforcement, DOJ and OFAC...more

The Volkov Law Group

DOJ, Commerce and Treasury Issue JCN on Foreign Person Liability for Sanctions and Export Controls Violations

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As DOJ, OFAC and BIS ramp up sanctions and export controls enforcement, they have continued to provide important compliance guidance.  You have to give the enforcement agencies credit — on the one hand, they regularly warn of...more

Adams & Reese

International Compliance Digest – March 2024

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International Compliance Digest is the new Adams and Reese monthly newsletter focused on international trade compliance and enforcement. Each month we will bring you the latest in compliance and enforcement updates, including...more

Wiley Rein LLP

Wiley's 10 Key Trade Developments: Evolution of Export Controls

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Along with engaging in closer cooperation with partner countries, the U.S. is prioritizing its own national security interests as well, moving first in many respects....more

ArentFox Schiff

US Sanctions Hundreds More on Second Anniversary of Russia’s Invasion, Highlights Perils of Continuing Business in Russia, But...

ArentFox Schiff on

Two years after the start of Russia’s war in Ukraine and one week after the death of opposition politician and anticorruption activist Aleksey Navalny, the US government announced a new raft of sanctions and export controls...more

Wiley Rein LLP

Wiley’s Top 10 Trade Developments: Heightened Sanctions and Export Control Enforcement

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This week’s video comes from partner Lori Scheetz, who discusses heightened U.S. enforcement of sanctions and export control laws, including how the government is prioritizing the prosecution of evasion efforts and other...more

Foley & Lardner LLP

What Every Multinational Company Should Know About . . . Implementing an International Compliance Program (Part I)

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Record penalties for violations of U.S. regulations governing international conduct and transactions illustrate the risk of costly enforcement actions facing multinational companies. Yet, many multinational companies lack...more

Akin Gump Strauss Hauer & Feld LLP

Tri-Seal Compliance Note: Voluntary Self-Disclosure of Potential Violations

On July 26, 2023, the departments of Commerce, Justice and the Treasury issued their second ever to date “Tri-Seal Compliance Note” (the “Note”). It describes expectations for the voluntary disclosure of sanctions, export,...more

The Volkov Law Group

Microsoft Pays OFAC and BIS Over $3.3 Million for Violations of Multiple Sanctions Programs (Part I of II)

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OFAC announced only one settlement in the first three months of 2023.  Given its ongoing role in the implementation and enforcement of Russia Sanctions, OFAC’s enforcement record so far is completely understandable.  The...more

Skadden, Arps, Slate, Meagher & Flom LLP

New US Efforts To Prosecute Sanctions Evasion and Export Control Violations May Require Compliance Programs To Be Updated

DOJ Increases Resources To Investigate and Prosecute Sanctions Evasion and Export Control Violations - On March 2, 2023, during a keynote speech at the American Bar Association’s annual White Collar Crime National...more

The Volkov Law Group

DOJ, and Departments of Commerce and Treasury Issue Joint Compliance Note on Evasion of Russia Sanctions and Export Controls

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As we have noted on numerous occasions, the U.S. Russia Sanctions and Export Control Program is unprecedented and a compliance challenge for all organizations. In another unprecedented action, the Justice Department and the...more

The Volkov Law Group

Commerce Department Tacks to New Aggressive Enforcement Program

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The Commerce Department’s Bureau of Industry and Security (“BIS”) has decided to join the enforcement club.  BIS’s recent announcement of new policies to administrative actions should not be surprising.  ...more

Hogan Lovells

Treasury Department issues inter-agency business advisory on Burma

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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

Lowenstein Sandler LLP

Trade Matters, January 2022: A monthly newsletter covering global trade & national security developments

1. New Import Ban on All Products From China’s Xinjiang Region- In late December 2021, President Biden signed the Uyghur Forced Labor Prevention Act into law. The new legislation creates a rebuttable presumption that any...more

Bracewell LLP

Biden Administration Prioritizes Increased and Broadened Anti-Corruption Enforcement

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On June 3, 2021, the White House issued a memorandum announcing anti-corruption as a core national security interest. The memorandum explains that, “[c]orruption threatens United States national security, economic equity,...more

The Volkov Law Group

SAP’s Comprehensive Export Control and Sanctions Settlement – A New Compliance Frontier for Cloud-Based Services (Part III of IV)

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The Justice Department’s National Security Division used the SAP comprehensive settlement of export control and sanctions violations to send a message – a loud and clear one....more

The Volkov Law Group

SAP’s Export Control and Sanctions Failures Results in Numerous Violations of Iran Sanctions Program (Part II of IV)

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When reviewing factual reports of global corporate failures – be it FCPA, sanctions, export controls, or anti-money laundering schemes and systemic misconduct schemes – the story appears to follow a familiar pattern....more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - April 2020

ANTICORRUPTION DEVELOPMENTS - New Guilty Plea in College Admissions Scandal - On April 21, 2020, Jorge Salcedo, a former tennis coach at a prominent California university, entered into a plea agreement related to his...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - February & March 2020

IN THIS ISSUE - • Anticorruption Developments • Export Control Sanctions and Customs Enforcement • Export Control and Sanctions Developments • Global Investigations Resources • Writing and Speaking Engagements ...more

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