Episode 319 -- Deep Dive into SCG Plastics' $20 Million Settlement with OFAC for Violations of the Iran Sanctions Program
Jones Day Talks: Italy Embraces Foreign investment but Maintains Oversight
Jones Day Talks: Doing Deals Down Under: Australia's Foreign Direct Investment Regime
FCPA Compliance and Ethics Report-Episode 66-Visit with the FCPA Professor
The table below presents a structured timeline of executive actions, policy directives, and trade-related decisions issued by President Trump’s administration from January 2025 to the present. It focuses on critical areas...more
The US State Department has made its first round of designations pursuant to Executive Order 14157, “Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists,”...more
The designations expand US tools and jurisdictional reach, and raise the stakes for foreign financial institutions and non-US companies to avoid dealing with designated entities....more
Throughout 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control ("OFAC") published 12 enforcement actions regarding alleged sanctions violations by foreign and domestic persons and entities....more
Last week, the U.S. Department of Defense (DOD) published a proposed rule that would amend the Defense Federal Acquisition Regulation Supplement (DFARS) to implement a statutory prohibition on DOD awarding contracts with...more
OFAC is capable of extending a long-arm of enforcement, reaching sometimes non-U.S. companies that may “cause” another company to violate U.S. Sanctions laws. If you need to find an example of this long reach, look no...more
On February 8, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced the imposition of sanctions against a network of foreign entities and a vessel involved in an asserted price cap...more
Grants and tax credits, who doesn’t love them? The Bipartisan Infrastructure Law (BIL) is full of them, and, recent Department of Energy (DOE) Notification of a Proposed Interpretive Rule provides guidance on who will get to...more
1. Seagate Technology Gets Largest-Ever BIS Penalty for Sales to Huawei- Seagate Technology LLC recently incurred a $300 million civil penalty from U.S. Department of Commerce’s Bureau of Industry and Security (BIS) due to...more
Tornado Cash, a cryptocurrency mixer, recently suffered two major setbacks in federal regulatory efforts to block its use and prosecute its founders. First, a federal district court threw out a lawsuit challenging the...more
For financial institutions and businesses that are subject to the oversight of the Office of Foreign Assets Control (OFAC), compliance needs to be a priority in 2023. OFAC is playing an increasingly active role in overseeing...more
July saw two noteworthy Russia enforcement actions. A Russian national was arrested in Estonia and extradited to the United States after being charged with conspiring to procure U.S.-origin technologies and ammunition on...more
On May 19, 2023 the United States, in coordination with the G7 and other international partners, imposed more than three-hundred new sanctions on Russia for its war in Ukraine. Press releases providing additional information...more
On January 5, 2023, President Biden ushered in the new year by signing into law the Protecting American Intellectual Property Act of 2022 (“PAIPA”), Pub. Law 117-336.1 PAIPA was passed with considerable bipartisan support in...more
The U.S. government issued guidance on October 14, 2022, emphasizing that the United States is “prepared to use its broad targeting authorities against non-U.S. persons” who continue to trade with Russia sanctions targets,...more
Outsourcing the design and manufacturing of products, components and software to foreign contractors has become a significant part of manufacturing in the U.S. However, if the items involved are subject to U.S. export...more
As Russia’s invasion of Ukraine persists, with no end currently in sight, the United States continues to issue increasingly punishing economic sanctions and export controls targeting Russia, most recently aiming at the...more
In the latest turn of events in the seemingly never-ending political saga of the Nord Stream 2 pipeline, the U.S. House of Representatives (the “House”), via an amendment to the 2022 National Defense Authorization Act...more
On June 3 of this year, the Biden Administration made plain its commitment to fighting corruption around the world, releasing a document identifying the fight against corruption “as an economic and national security priority”...more
The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) published final rules on January 15, 2021, implementing the sanctions put in place by Executive Order 13936 (EO 13936) and the Hong Kong Autonomy Act...more
China has recently introduced unreliable entity list ("Entity List") regulations to provide a framework for China's upcoming list of economic sanctions. As early as October 2018 and March 2020, China has implemented "blocking...more
Newly issued Unreliable Entity List (“UEL”) regulations establish a framework for list-based economic sanctions to be administered by China. Viewed together with “blocking statutes” implemented in March 2020 and October 2018...more
On May 2, 2019, OFAC (Office of Foreign assets Control) published guidance titled “A Framework for OFAC Compliance Commitments”. The purpose of the OFAC Framework guidance is to encourage a “risk-based” approach to...more
Organization Excels at Niche Branding but Stumbles in Avoiding Enforcement - The first paragraph of the press release sums it up: Today the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) took action...more
On May 2, 2019, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”)—the U.S. agency tasked with administering and enforcing the U.S.’s economic and trade sanctions programs—published A Framework for...more