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National Security Sanction Violations

Ankura

Navigating OFAC Sanctions Risks in the Digital Realm: IP Addresses and Effective Controls

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In today's digital landscape, sanctions enforcement has become a critical concern for Financial Institutions (FIs). The borderless nature of cyberspace can make it difficult to monitor and regulate activities that may breach...more

Braumiller Law Group, PLLC

Hot Topics in International Trade - June 2024 - New Legislation Extends Statute of Limitations for Sanctions Violations

Recently, President Biden signed a foreign military support bill (H.R. 815) into law, which also encompassed the 21st Century Peace Through Strength Act (the Act), a legislative proposal introduced in the House containing...more

Akin Gump Strauss Hauer & Feld LLP

DOJ Announces First-Ever Corporate Declination Under National Security Division’s Voluntary Self-Disclosure Program

Key Points - On May 21, 2024, the DOJ announced its first ever declination under the NSD’s updated Enforcement Policy, declining to prosecute Sigma-Aldrich Inc., d/b/a MilliporeSigma (a subsidiary of Merck KGaA, Darmstadt,...more

Blank Rome LLP

President Biden Signs into Law Ten-Year Statute of Limitations for Sanctions Violations and Other National Security Measures

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President Biden last month signed into law H.R. 815 (“National Security Supplemental” or “NSS”). The NSS—a package of national security and foreign aid appropriations, including for efforts in Israel, Ukraine, and the...more

Akin Gump Strauss Hauer & Feld LLP

Congress Extends Statute of Limitations for Sanctions and Certain Other National Security Programs from 5 to 10 Years and...

While media reporting has predominantly focused on the provisions in the emergency foreign aid package that President Biden signed into law on April 24, 2024 that provides funding for Ukraine, Israel and Taiwan, House Foreign...more

Eversheds Sutherland (US) LLP

National Security Act of 2024 extends statute of limitations for sanctions violations to 10 years

The measure also harmonizes Russia sanctions rules with allies, and intensifies penalties against Iran - The National Security Act, 2024 (Pub. L No 118-50) was enacted on April 24, 2024. In addition to the Act’s provisions...more

Guidepost Solutions LLC

3 Key Factors in Safeguarding National Security: Economic Sanctions, Voluntary Self-Disclosures, and Whistleblower Retaliation

Companies and their executives can reduce Department of Justice (DoJ), OFAC, and Commerce Department risks (and liability) by understanding and respecting the relationship between economic sanctions, voluntary...more

Mayer Brown

US DOJ’s National Security Division Updates Enforcement Policy for Criminal Sanctions and Export Control Violations with New Focus...

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On March 7, 2024, the US Department of Justice’s National Security Division (NSD) released a revised Voluntary Self-Disclosure (VSD) Policy (the “VSD Policy”). The VSD Policy substantially tracks the language of the previous...more

K2 Integrity

FINCast Ep. 39 – State of Russia Sanctions Two Years After the Invasion

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On FINCast Episode 39, Juan Zarate sits down with K2 Integrity’s Katya Hazard and Amir Fadavi to discuss the state of Russia-related sanctions and to explore what has worked and what may require further coordinated efforts to...more

Snell & Wilmer

United States Announces Largest Round of Sanctions Since the Start of Russia’s War in Ukraine

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The U.S. Government recently announced the largest round of sanctions against the Russian Federation (Russia) since the invasion of Ukraine two years ago. This multi-agency effort enacted over 500 sanctions against foreign...more

Ballard Spahr LLP

The American Front in Russia’s War on Ukraine: DOJ’s “Task Force KleptoCapture” Continues Focus on Operations of Sanctioned...

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We previously have blogged on actions taken by the DOJ’s “Task Force KleptoCapture,” an interagency law enforcement task force with a mandate to target sanctioned Russian and pro-Russian oligarchs. While explicitly launched...more

Seward & Kissel LLP

The Importance of Sanctions and Export Control Compliance

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The United States manages more than three dozen separate economic and trade sanctions programs. Those programs target specified foreign governments along with thousands of named individuals, groups and entities in accordance...more

Whitcomb Selinsky, PC

Illegal Export Scheme: US Seizes Funds in Civil Forfeiture Action

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In a recent legal breakthrough that highlights the importance of ITAR compliance and arms regulation, the United States has achieved a significant milestone. Through a rigorous investigation into an illicit scheme involving...more

Bracewell LLP

DOJ Spotlights Voluntary Self Disclosure in M&A as it Adapts to New National Security Threats

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The past few months have seen numerous high-profile enforcement actions highlighting an increasing trend, what Deputy Attorney General Lisa Monaco called “the biggest shift in corporate criminal enforcement that I’ve seen...more

American Conference Institute (ACI)

Navigating U.S. Sanctions and Export Control Restrictions

Over the last several months, companies have become entangled in an increasingly complex web of new and expanded sanctions and export control restrictions related to Russia in response to its war on Ukraine. The current...more

Oberheiden P.C.

OFAC Compliance: Developing and Implementing an Effective Sanctions Compliance Program

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Financial institutions and companies that are subject to oversight from the Office of Foreign Assets Control (OFAC) need to prioritize compliance. OFAC has become increasingly active in recent years, and it is devoting...more

Oberheiden P.C.

OFAC Compliance: Avoiding Common Root Causes of Compliance Policy Breakdowns and Deficiencies

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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

Oberheiden P.C.

Ten Strategic Considerations for OFAC Appeals

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The Office of Foreign Assets Control (OFAC) has oversight of financial transactions involving U.S. and foreign entities. It exercises this authority in several ways, including (i) through the administration of its various...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – July 2023 Update

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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

Akin Gump Strauss Hauer & Feld LLP

Tri-Seal Compliance Note: Voluntary Self-Disclosure of Potential Violations

On July 26, 2023, the departments of Commerce, Justice and the Treasury issued their second ever to date “Tri-Seal Compliance Note” (the “Note”). It describes expectations for the voluntary disclosure of sanctions, export,...more

Akerman LLP

The Art of Coming Clean: Agencies Provide Guidance on Voluntary Self-Disclosures of Export Controls and Sanctions Violations

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On June 26, 2023, the Departments of Justice, Commerce, and Treasury issued a Tri-Seal Compliance Note that summarizes agency policy memoranda and existing regulations on voluntary self-disclosures (VSDs) of export controls...more

Latham & Watkins LLP

US Sanctions and Export Control Agencies Issue “Joint Compliance Note” on Voluntary Self-Disclosure Policies

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Companies that promptly self-disclose and remediate potential violations of administrative or criminal law may significantly mitigate liability. On July 26, 2023, the US Departments of Justice (DOJ), Commerce, and the...more

Holland & Knight LLP

Tri-Seal Compliance Note Issued on Export Controls, Sanctions Violations Self-Disclosures

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The U.S. Department of Justice (DOJ), Department of Commerce's Bureau of Industry and Security (BIS) and Department of the Treasury's Office of Foreign Assets Control (OFAC) on July 26, 2023, issued a Tri-Seal Compliance Note...more

American Conference Institute (ACI)

[Event] 17th Annual Flagship Conference on U.S. Economic Sanctions Enforcement and Compliance - April 25th - 26th, Washington, DC

The American Conference Institute is hosting their 17th Annual Flagship Conference on U.S. Economic Sanctions Enforcement and Compliance on April 25-26, 2023, in Washington! Don’t miss the opportunity to stay current with the...more

American Conference Institute (ACI)

Compliance measures to address sanctions enforcement: ‘the new FCPA’

In line with the Biden administration’s declaration last year that anticorruption is a “core United States national security interest,” sanctions evasion enforcement rapidly has become a core priority for the Department of...more

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