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Williams Mullen's COVID-19 Comeback Plan: Part I – Doing Business With the Commonwealth of Virginia
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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
In this weekly update, we summarise the most notable updates in the UK sanctions world. ...more
On December 22, 2023, President Biden signed the National Defense Authorization Act for Fiscal Year 2024 into law after bipartisan congressional majorities approved the bill earlier in the month. The annual bill authorizes...more
On September 26, 2023, U.S. export enforcement authorities, jointly with enforcement authorities in four allied countries (the Five Eyes), issued additional guidance in order to prevent the diversion of goods in violation of...more
The Justice Department has touted the upcoming wave of corporate prosecutions for criminal sanctions violation as the era of “The New FCPA.” DOJ’s reference is intended to communicate a strong message – companies are going to...more
In a relatively rare move for four (4) Cabinet-level Departments, the U.S. Departments of Commerce, Justice, State and Treasury issued an advisory notice on June 9, 2023, aimed specifically at reminding industry of their...more
Over an eight-year period ending in 2018, Murad, a U.S. cosmetics company, illegally exported goods and services to Iran in 62 separate transactions worth approximately $11 million. Murad was acquired by Unilever United...more
K2 Integrity delivers information and analysis on recent developments related to sanctions against Russia and key implications for the public, private, and non-profit sectors as the United States (U.S.), the European Union...more
On March 9, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions against a China-based network of five companies and one individual accused of supporting Iran’s unmanned aerial vehicle...more
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
On March 1, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced a $332,500 settlement with an India-registered tobacco company to resolve allegations that it “requested payment in U.S. dollars for...more
In this post, we describe the many sanctions imposed by Canada on Russia and Belarus, and on certain Ukrainians who have supported them, since our previous update on June 22, 2022. ...more
The uptick in recent sanctions activity caused in large part by the Russian Federation’s unprovoked and unilateral invasion of Ukraine has caused absolute pandemonium in many compliance circles. While the U.S. Department of...more
Given the recent expansion of the regulatory landscape in light of the ongoing events in Russia and Ukraine, namely the imposition of extensive sanctions on Russia (and certain Russian banks and nationals), there has been a...more
You have to wonder how OFAC has the time to investigate and settle cases given its significant work implementing the Russia Sanctions Program. But OFAC continues to demonstrate its commitment to aggressive enforcement. ...more
On March 2, 2022, as part of a string of sanctions and export controls, the Russia/Belarus Foreign Direct Product (“FDP”) Rule and Russia/Belarus-Military End User (“MEU”) FDP Rule took effect. These rules, generally,...more
On February 24, 2022, Canada imposed additional sanctions on Russia in the wake of its invasion of Ukraine. The new sanctions, the key elements of which are described below, are now effective and were imposed under...more
In response to Russia’s invasion of Ukraine territories, the so-called Donetsk and Luhansk People’s Republics, respectively, (hereinafter “DNR” and “LNR”), on February 21, 2022, President Biden issued a new Executive Order...more
OFAC is off to a quick start in 2022. After announcing its Airbnb enforcement action in the beginning of January, OFAC announced a settlement with Sojitz (Hong Kong) Limited, a Hong Kong, China-based company that engages in...more
In May 2019, OFAC released its Framework for a Sanctions Compliance Program. OFAC announced that it intended to increase the prosecution of individuals for sanctions violations. OFAC has brought two cases against...more
In an interesting announcement, the US, EU, UK and Canada implemented additional sanctions against Belarus. The coordinated announcement reflected the Biden Administration’s diplomatic commitment to joint sanctions actions. ...more
On November 12, 2021, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”), pursuant to Executive Order 14046, Imposing Sanctions on Certain Persons With Respect to the Humanitarian and Human Rights...more
We have heard it over and over, again and again – third-parties pose significant risks of bribery for all global businesses. Almost every FCPA enforcement action includes some form of third-party misconduct. The current...more
In the second OFAC enforcement action released on the same day, September 27, 2021, Schlumberger Rod Lift, Inc. (“SRL”) (now d/b/a Lufkin Rod Lift, Inc.), and formerly a subsidiary of Schlumberger Lift Solutions LLC (“SLS”),...more
In a pair of enforcement actions, OFAC settled two separate actions involving Schlumberger Limited subsidiaries – the first involving Cameron International Corporation, and the second, Schlumberger Rod Lift, Inc., a former...more