News & Analysis as of

Interim Final Rules (IFR)

Morrison & Foerster LLP

OFAC Extends Recordkeeping Requirements from Five to 10 Years; Issues Paperwork Reduction Act Request for Comments

On September 11, 2024, OFAC announced its Interim Final Rule to Extend Recordkeeping Requirements from Five to 10 Years. The Interim Final Rule (IFR) was published in the Federal Register on September 13, 2024. Public...more

Dorsey & Whitney LLP

Commerce Department Adopts Sweeping Changes in U.S. Export Controls

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On September 6, the Bureau of Industry and Security (“BIS”) in the U.S. Commerce Department issued an interim final rule (“IFR”) under the Export Administration Regulations (“EAR”) to add new export controls on semiconductor,...more

Blank Rome LLP

BIS Issues New Export Controls Targeting GAAFET, Quantum, and Additive Manufacturing, and Ushers in New Age of Plurilateral Export...

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The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) recently issued an interim final rule (“IFR”) under the Export Administration Regulations (“EAR”) imposing licensing requirements for exports to all...more

Holland & Knight LLP

Major Export Controls Revisions and the AUKUS Trilateral Security Partnership

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The U.S. Department of Commerce and U.S. Department of State have been continuously easing restrictions on export-controlled trade between the United States, United Kingdom and Australia to foster technological innovation...more

Troutman Pepper

Texas Federal District Court Rejects All Administrative Procedure Act Challenges to CFPB’s Section 1071 Final Rule

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Monday, the U.S. District Court for the Southern District of Texas granted the Consumer Financial Protection Bureau’s (CFPB or Bureau) motion for summary judgment on all Administrative Procedure Act (APA) challenges brought...more

BakerHostetler

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

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In 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 sanctions imposed by...more

Davis Wright Tremaine LLP

Deadline Approaching for Filing 2024 OFAC Annual Report of Blocked Property

The annual September 30 deadline for submitting the Annual Report of Blocked Property (ARBP) to the U.S. Department of Treasury Office of Foreign Assets Control (OFAC) is fast approaching. Under federal regulations, "all U.S....more

Seyfarth Shaw LLP

BIS Publishes Interim Final Rule on “Standards-Related Activities"

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On July 18, 2024, the U.S. Dept. of Commerce, Bureau of Industry and Security (BIS) published a new interim final rule (the “Interim Final Rule”) entitled “Standards-Related Activities and the Export Administration...more

Foley Hoag LLP

OFAC Issues Guidance Concerning Statute of Limitations Extension

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On April 24, 2024, President Biden signed into law the 21st Century Peace through Strength Act, Pub. L. No. 118-50 (the “Act”). By doing so, the statute of limitations (“SoL”) for violations, both criminal and civil, of IEEPA...more

Fenwick & West LLP

Access Control and Emerging Tech Remain Top Priorities in BIS Regulatory Agenda

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The Bureau of Industry and Security (BIS) has published its spring 2024 regulatory agenda along with the rest of the Commerce Department. Of note is the continued focus on access to emerging technology, particularly relating...more

Seward & Kissel LLP

Compliance Flash: OFAC Announces New Reporting Requirement for Financial Institutions Under the REPO for Ukrainians Act

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The supplemental appropriations legislation signed into law on April 24, 2024 enacted numerous high-profile provisions addressing aspects of U.S. foreign policy and national security, including provisions that broaden and...more

Holland & Knight LLP

CFPB Proposes New Restrictions on Mortgage Servicers Before Commencing Foreclosures

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The Consumer Financial Protection Bureau (CFPB) on July 10, 2024, announced a proposed rule that would require servicers to more intently assist borrowers throughout a "loss mitigation review cycle" before being permitted to...more

Fenwick & West LLP

OFAC Publishes Guidance on 10-Year Sanctions Violations Statute of Limitations

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On July 22, 2024, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) issued guidance addressing the April 2024 extension of the statute of limitations for sanctions violations from five years to 10...more

Davis Wright Tremaine LLP

OFAC Provides Guidance on Extended Statute of Limitations

As we previously reported, effective April 24, 2024, the statute of limitations for most civil and criminal violations of the International Emergency Economic Powers Act (IEEPA) or the Trading with the Enemy Act (TWEA) has...more

Ballard Spahr LLP

CFPB Releases Interim Final Rule Extending 1071 Compliance Dates

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On June 25th, the CFPB issued an interim final rule with a request for public comment extending the compliance dates for the Small Business Lending Rule in light of the Supreme Court’s decision finding the funding structure...more

Troutman Pepper

CFPB Issues Interim Final Rule Memorializing Updated Compliance Dates for Section 1071 Final Rule

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As discussed here, following the U.S. Supreme Court’s decision in Community Financial Services Association of America, Limited v. Consumer Financial Protection Bureau (CFPB or Bureau), which upheld the CFPB’s funding...more

Lowenstein Sandler LLP

Trade Matters - Lowenstein Sandler's Global Trade & National Security Newsletter - June 2024

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On May 10, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an Interim Final Rule (IFR), effective August 8, 2024, that updates the Reporting, Procedures, and Penalties Regulations....more

Groom Law Group, Chartered

Expanded Abandoned Plan Program Gives Certain Bankruptcy Trustees QTA Eligibility, Adopts Other Technical Changes

On May 17, 2024, the Department of Labor (“DOL”) published interim final rules (collectively, the “IFR”) to amend DOL’s 2006 regulations establishing the abandoned plan program, as well as the accompanying prohibited...more

Akin Gump Strauss Hauer & Feld LLP

OFAC Revamps Reporting Requirements

Key Points - On May 10, 2024, OFAC issued an IFR that would amend its Reporting, Procedures and Penalties Regulations (RPPR) at 31 C.F.R. Part 501 to, among other things, modify certain reporting requirements pertaining to...more

Bracewell LLP

OFAC Expands Recordkeeping Requirements, Mandates Electronic Filings

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Last week, the Office of Foreign Assets Control (OFAC) announced an interim final rule which amends the recordkeeping and reporting requirements relating to the various economic sanctions programs it enforces. Notably, the...more

Wiley Rein LLP

DDTC and BIS Ease Export Controls for Australia and the United Kingdom - UPDATED May 10, 2024

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*This alert was originally published on May 3, 2024 and updated on May 8, 2024 based on a correction published by BIS that day. The U.S. Department of State’s Directorate of Defense Trade Controls (DDTC) issued a proposed...more

The Volkov Law Group

New BIS Rule Implementing AUKUS Effectuates Sweeping Changes to Dual Use Export Controls

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On April 19, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) published an interim final rule (“IFR”) that officially codifies certain changes to the Export Administration Regulations (“EAR”)...more

Wiley Rein LLP

Commerce Announces New Restrictions on Firearms Exports, Ends Commercial Firearms Exports to 36 Countries and Revokes Existing...

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On April 25, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced in a press release that it will publish an interim final rule (IFR) in the Federal Register on April 30, 2024, updating the...more

Davis Wright Tremaine LLP

Banking and Consumer Regulatory Digest - March 2024 - 2

Editor's Note - The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency,...more

Hogan Lovells

The Commerce Department expands and clarifies the controls in the October 2023 Semiconductor Rules

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The Department of Commerce’s Bureau of Industry and Security published an interim final rule to expand, correct, and clarify the two interim final rules published on October 25, 2023 with respect to semiconductor...more

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