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ArentFox Schiff

As the (Customs and Trade) World Turns: September 2024

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Welcome to the September 2024 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and...more

Hogan Lovells

U.S. proposes revisions to “defense service” definition and related export controls

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On July 29, 2024, the U.S. Department of State’s Directorate of Defense Trade Controls (DDTC) issued a proposed rule to revise the definition of “defense service” and the scope of related controls under existing International...more

White & Case LLP

Sanctions move up the agenda for lenders and borrowers

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Compliance with sanctions regimes has been a priority for debt markets. Amid rising geopolitical tensions, the stakes for lenders and borrowers are higher than ever - Intensifying geopolitical tensions and the US...more

BakerHostetler

Current State of U.S. Economic Sanctions Imposed in Response to Russia’s Invasion of Ukraine - August 2024 #2

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

Akin Gump Strauss Hauer & Feld LLP

Significant New U.S. Person and Other Export Controls Proposed Regarding Military, Intelligence, and Security End Users

The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) has published proposed amendments to the Export Administration Regulations (EAR) that would significantly expand the scope of the export controls over...more

Adams and Reese LLP

International Compliance Digest – July 2024

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July was a big month for compliance with a handful of reports and recommendations on due diligence and best practices concerning forced labor, export controls, sanctions from DHS, BIS, and OFAC. The below updates also...more

WilmerHale

BIS Sets Higher KYC Standards for Companies and Universities Over Russia Diversion Concerns

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On July 10, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) released new guidance (the “July 10 Release”) outlining different types of precautionary letters (“supplier list” letters, “Project...more

Holland & Knight LLP

New Requirements for Research Security Programs Raise the Stakes for Compliance

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The National Security Presidential Memorandum-33 (NSPM-33), issued in January 2021, directed federal agencies that fund research and development (R&D) projects to require certain "Covered Institutions" to certify that the...more

Kelley Drye & Warren LLP

BIS Issues Guidance on Addressing Export Diversion Risks

On July 10, the Department of Commerce’s Bureau of Industry and Security (BIS) published guidance on how to identify parties that present a heightened risk of diversion to Russia’s military-industrial sector, as well as...more

Hogan Lovells

Significant new measures against Russia issued by US Departments of Treasury, State, and Commerce

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On 12 June 2024, the US Departments of Treasury, State, and Commerce imposed new restrictions targeting Russia, including: (i) restricting the provision of certain information technology and software services to Russia...more

Adams and Reese LLP

International Compliance Digest - June 2024

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Sanctions and export controls were the top items of interest in June. On the compliance side, OFAC and the BIS announced new sanctions and export controls on Russia and Belarus. The new measures target individuals and...more

Blank Rome LLP

New Russia Sanctions Target IT Services, Enterprise Management Software, and Foreign Financial Transactions

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) and the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) recently issued a significant new round of sanctions and export...more

Orrick, Herrington & Sutcliffe LLP

Sweeping New U.S. Sanctions and Export Controls Intensify Pressure on Russia and Belarus As Russia Transitions to a Full War...

The United States has substantially expanded economic sanctions and export controls targeting Russia and Belarus, imposing new restrictions that could have a major impact on companies with business activities in or relating...more

Wilson Sonsini Goodrich & Rosati

Biden Administration Further Expands Export Controls and Sanctions on Russia and Belarus

On June 12, 2024, ahead of the 2024 G7 Summit, the Biden administration introduced new export controls and sanctions on Russia and Belarus in an effort to limit Russia’s ability to continue its war efforts against Ukraine....more

Sheppard Mullin Richter & Hampton LLP

Now Including the Kitchen Sink: Expansion of Export Controls on Russia Adds Restrictions on Low-Level Items and Software

Last year, we published an update on BIS’s foray into prohibiting EAR99 items for export to Russia and Belarus. We noted (somewhat in jest) that kitchen sinks may one day be added. Well, that day has come. Stainless steel...more

Dechert LLP

U.S. Sanctions Russian Financial Infrastructure

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On the eve of the 2024 Group of Seven (G7) Leaders’ Summit, the United States imposed new sanctions and export control measures against Russia further targeting sanctions evaders and, for the first time, the Russian...more

White & Case LLP

The Shadow Financial System

White & Case LLP on

The concept of the shadow financial system rose to international prominence in the aftermath of the 9/11 terrorist attacks. In an interview with a Pakistani newspaper a month later, Osama bin Laden stated that Al Qaeda were...more

ArentFox Schiff

US Government Throws “Kitchen Sink” Export Controls at Russia, Plus Sweeping EAR99 Software Controls, and IT and Software Services...

ArentFox Schiff on

Three US agencies – the US Department of Commerce, Bureau of Industry and Security (BIS), the US Department of the Treasury, Office of Foreign Assets Control (OFAC), and the US Department of State – took new actions on June...more

Fenwick & West LLP

U.S. Imposes Sweeping New Sanctions and Export Controls on Russia and Belarus, including on Certain Software and Related Services

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Citing Russia’s “transition to a full war economy,” the United States imposed sweeping new sanctions and export controls on Russia and Belarus today, including companies and individuals that continue to supply Russia’s...more

Pillsbury - Global Trade & Sanctions Law

Treasury Amends the Cuban Assets Control Regulations to Support Cuban Citizens and Independent Private Sector Entrepreneurs

On May 28, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) amended the Cuban Assets Control Regulations (CACR) to better implement the Biden-Harris Administration’s policy aimed at...more

Wiley Rein LLP

Treasury Department Amends Cuba Sanctions, Expands Access to Internet and Financial Services for Cuban Nationals

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On May 28, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced amendments to the Cuban Assets Control Regulations (CACR), which expand authorizations for certain financial and...more

Fenwick & West LLP

Latest Updates in Trade Controls for the Tech Sector

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Melissa Duffy and Trevor Coval contributed their thought leadership to the American Conference Institute’s 14th Annual Global Encryption, Cloud & Cyber Export Controls Conference, held in San Francisco on May 14-16. Melissa...more

K2 Integrity

U.S. Congress Mandates Wide Range Of Sanctions In Ukraine, Israel, And Taiwan Aid Bill

K2 Integrity on

On 24 April 2024, President Biden signed into law H.R. 815, “Making Emergency Supplemental Appropriations for the Fiscal Year Ending September 30, 2024, and for Other Purposes” (the Act). The long-awaited piece of legislation...more

The Volkov Law Group

DOJ and OFAC Sanctions and Export Control Detection Strategies

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In this new aggressive era of sanctions and export controls enforcement, companies need to understand the potential risks that DOJ and/or OFAC may identify a company for sanctions investigation....more

Pillsbury - Global Trade & Sanctions Law

State Department Proposes Exempting Australia, UK from Certain Defense Related Export Controls

On April 30, 2024, the Department of State proposed an amendment to the International Traffic in Arms Regulations (ITAR) intended to facilitate exports of defense articles, the performance of defense services, and brokering...more

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