News & Analysis as of

Export Controls Bureau of Industry and Security (BIS) Office of Foreign Assets Control (OFAC)

Wilson Sonsini Goodrich & Rosati

From Embargo to Engagement: U.S. Reopens Doors to Syria

After the fall of the former regime of Bashar al-Assad in Syria, the Presidential Administration has taken steps to formally dismantle the U.S.’s two-decade-long comprehensive trade restrictions on Syria. These steps began...more

Troutman Pepper Locke

With Additional Syria Sanctions Relief, Risks Remain

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On June 30, 2025, President Trump issued an executive order (EO) that, effective July 1, revokes the U.S. sanctions program on Syria, and calls for the removal of the Syrian Sanctions Regulations from the Code of Federal...more

Kelley Drye & Warren LLP

White House Terminates Most Syria Sanctions

On June 30, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) implemented the President’s Executive Order ​“Providing for the Revocation of Syria Sanctions,” (Syria EO) which removes U.S. sanctions on...more

A&O Shearman

DOJ Issues First-Ever Declination For Sanctions Violations Since Creation Of The M&A Safe Harbor Policy

A&O Shearman on

On June 16, 2024, the U.S. Department of Justice’s (“DOJ”) National Security Division (“NSD”) and the U.S. Attorney’s Office for the Southern District of Texas (“SDTX”) announced the first-ever declination to prosecute a firm...more

McDermott Will & Emery

From risk to relief: PE firm avoids prosecution with swift disclosure

In June 2025, the US Department of Justice (DOJ) announced that it declined to prosecute a private equity firm and its affiliates following the firm’s voluntary self-disclosure of criminal violations of US sanctions and...more

Proskauer Rose LLP

DOJ Declination of Private Equity Firm Underscores Need for Robust M&A Due Diligence

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On June 16, 2025, the U.S. Department of Justice (“DOJ”), including its National Security Division (“NSD”) and the U.S. Attorney’s Office for the Southern District of Texas, announced that they would not prosecute White Deer...more

The Volkov Law Group

DOJ’s Coordinated Resolution with Unicat Resolves OFAC, BIS and CBP Violations (Part II of III)

The Volkov Law Group on

DOJ’s Unicat resolution is a perfect example of the new trade enforcement reality under the Trump Administration.  DOJ spearheaded a global resolution of sanctions, customs and export controls violations, while declining to...more

The Volkov Law Group

Unicat Settles with DOJ and Resolves Sanctions, Export Controls and Customs Violations Applying Voluntary Disclosure Policy in M&A...

The Volkov Law Group on

In an interesting enforcement action reflecting the Administration’s priority on sanctions, export and customs enforcement, DOJ announced a global resolution with DOJ, OFAC, BIS and CBP and Unicat Catalyst Technologies...more

White & Case LLP

DOJ Declines to Prosecute Private Equity Firm after Post-Acquisition Voluntary Self-Disclosure of Sanctions and Export Control...

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In its first application of the policy on voluntary self-disclosures (“VSDs”) in connection with mergers and acquisitions (“M&A”), on June 16, 2025, the US Department of Justice’s (“DOJ”) National Security Division (“NSD”)...more

Vinson & Elkins LLP

Commercial Considerations Related to the Shift in Syrian Sanctions Policy

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On May 23, 2025, General License 25 (“GL 25” or the “General License”) was issued by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), suspending a wide array of sanctions against Syria....more

Morrison & Foerster LLP

Trump Administration Issues Broad Sanctions Relief for Syria, Effectively Lifting 14 Years of Comprehensive Economic Sanctions –...

On May 23, 2025, 10 days after President Trump announced his directive to lift U.S. sanctions on Syria during his visit to Saudia Arabia last month, the U.S. Department of the Treasury’s Office of Foreign Assets Control...more

Hogan Lovells

OFAC lifts certain sanctions on Syria, broad export controls remain in place

Hogan Lovells on

General License (GL) 25 authorizes transactions previously prohibited by various regulations. Specifically, Section (a) broadly authorizes activities previously prohibited under the Office of Foreign Asset Control (OFAC)’s...more

WilmerHale

The United States and European Union Offer Sanctions Relief to Post-Assad Syria

WilmerHale on

Following the fall of Syria’s Assad regime, the United States and key allies have recently announced sanctions relief with the stated goal of stabilizing Syria under its newly installed leaders. ...more

Benesch

Syria Sanctions - New General License Issued by OFAC Following Trump Announcement

Benesch on

President Trump announced plans to relax sanctions against Syria during his recent trip to the Middle East, where he visited with the country’s President, Ahmed al-Sharaa. ...more

Husch Blackwell LLP

Week Seventeen in Trade

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CBP Issues Facility Requirements for Bonded Warehouses In a Cargo Systems Messaging Service (“CSMS”) message, U.S. Customs and Border Protection (“CBP”) clarified that bonded warehouses, as defined in 19 C.F.R. § 19.1, do...more

American Conference Institute (ACI)

[Event] Trade & Sanctions Compliance for the Oil and Gas Industry - May 21st - 22nd, Houston, TX

Between tariffs, tightening export controls, evolving sanctions, and ramped up enforcement, the cost and complexity of compliance is rising for oil and gas supply chains. ACI’s Trade & Sanctions Compliance for the Oil and...more

Foley & Lardner LLP

The Non-Compliant Cat in the Hat

Foley & Lardner LLP on

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

American Conference Institute (ACI)

[Event] 19th Annual Flagship Conference on Economic Sanctions Enforcement and Compliance - April 30th - May 1st, Washington, DC

With unprecedented change and intensifying enforcement, now is the time to ensure your team is prepared for what’s ahead. Ensure that you don’t miss out on critical U.S. and international economic sanctions updates and the...more

Foley Hoag LLP - White Collar Law &...

Review of International Trade Enforcement in the U.S., E.U., and UK in 2024 and What to Expect in 2025

This is the final in our 2025 Year in Preview series examining important trends in white collar law and investigations in the coming year. Throughout 2024, enforcement of international trade laws continued to gather pace...more

The Volkov Law Group

Israeli Freight Forwarder Sentenced to Two Years in Prison for Violating U.S. Export Controls on Aircraft Components to Russia

The Volkov Law Group on

The recent sentencing of Israeli freight forwarder Gal Haimovich to two years in federal prison for violations of U.S. export controls serves as a striking example of the aggressive enforcement posture adopted by U.S....more

Womble Bond Dickinson

International Trade in Goods and Technology: An Ever-Changing Regulatory Landscape

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Governments have long regulated international trade in goods, technology, and investment for purposes of revenue generation, economic policy, and national security....more

Bass, Berry & Sims PLC

Haas Automation Agrees to Pay More Than $2.5 Million to Settle Sanctions and EAR Violations

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On January 17, the Treasury Department’s Office of Foreign Assets Control (OFAC) and the Commerce Department’s Bureau of Industry and Security (BIS) announced that Haas Automation Inc. (Haas) agreed to settle potential civil...more

Husch Blackwell LLP

Week Three in Trade – First 100 Days of the New Administration

Husch Blackwell LLP on

We previously covered President Trump’s IEEPA tariffs and the various retaliatory tariff and nontariff countermeasures announced by each country in separate posts. Currently, the Mexico and Canada tariffs have been paused...more

Torres Trade Law, PLLC

DOJ’s Increasing Role in the Enforcement of U.S. Trade Laws

Multiple federal agencies are charged with enforcing U.S. international trade and national security laws. These agencies include the Department of Commerce Bureau of Industry and Security (BIS) and the Department of State...more

BakerHostetler

Current State of U.S. Economic Sanctions Imposed in Response to Russia’s Invasion of Ukraine - January 29, 2025

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In its continuing response to Russia’s ongoing invasion of Ukraine, the U.S. government has deployed a whole-of-government approach to impose sanctions and tighter export controls on Russia and Belarus. This alert summarizes...more

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