FINCast Ep. 19 - The DPRK Sanctions Program
As federal regulators have recently made clear, steamship lines, non-vessel-operating common carriers, indirect air carriers, freight forwarders, and others involved in the global movement of cargo must ensure that their...more
You are reading the April 2023 Update of the Bass, Berry & Sims Enforcement Roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox. -We saw...more
Companies should be prepared to conduct additional due diligence for any transactions involving entities in the countries enumerated in this rule. In an interim rule published on, January 15, 2020, the Department of...more
It seems almost every day there are reports of new developments under the U.S. sanctions laws. Yet many U.S. companies do not understand the significance of these laws....more
As trade compliance gains more traction, US regulators have made it clear that having compliance policies in place is critical, regardless of the company size or the industry. The implementation of such compliance programs...more
On December 20, 2019, President Trump signed into law the National Defense Authorization Act for Fiscal Year 2020 (“NDAA 2020”), which includes numerous sanctions-related provisions. The law includes the previously introduced...more
BIS has restricted Cuba’s access to commercial aircraft and other goods, lowered de minimis for foreign items containing US content to 10%, and restricted the temporary sojourn by aircraft in Iran, Syria, Sudan, and North...more
ANTICORRUPTION DEVELOPMENTS - DOJ Extends FCPA Corporate Enforcement Policy to Misconduct in Mergers and Acquisitions - On July 25, 2018, in a speech to the Ninth Global Forum on Anti-Corruption Compliance in High Risk...more
Despite our political dialogue and the often-heard charges of fake news and lying, telling the truth still matters in a variety of contexts. For example, Special Counsel Mueller has made various characters in the Russia...more
Recently, many revisions to U.S. sanction programs (both implemented and under consideration) have been the topic of much public discussion. Often, the legal status or these revisions may be difficult to determine....more
ANTICORRUPTION DEVELOPMENTS – Global Compliance Overhaul for SAP as DOJ and SEC Investigate Payments Allegedly Related to South African Government Contracts – On October 26, 2017, German software company SAP SE...more
On March 7, 2017, the United States announced that China’s Zhongxing Telecommunications Equipment Corporation and ZTE Kangxun Telecommunications Ltd. and their respective affiliates (collectively, ZTE) had agreed to a record...more
Overview of US and EU Trade Sanctions - Following is a summary of the current US and EU sanctions that restrict trade with and/or investment in certain countries, “Specially Designated Nationals” (SDNs) and “Blocked...more
Making regular updates to policies and procedures related to international trade compliance has always been an important aspect of ensuring their effectiveness, and particularly in light of the myriad changes to various U.S....more
The U.S. Department of State imposed sanctions on September 2, 2015, against 23 companies around the world for involvement in the transfer or purchase to or from Iran, North Korea or Syria of goods, services or technology...more
Recent actions by the U.S. Congress and several executive branch agencies have resulted in changes to sanctions related to various countries and regions, including Cuba, North Korea, Crimea, and Venezuela....more