News & Analysis as of

Office of Foreign Assets Control (OFAC) Enforcement

BakerHostetler

DOJ Implements Bulk Personal Data Transfer Restrictions

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The Data Security Program (DSP) recently implemented by the U.S. Department of Justice (DOJ) will have far-reaching implications for many businesses that transfer the personal data of U.S. citizens outside the United States....more

American Conference Institute (ACI)

[Event] 19th Annual Flagship Conference on Economic Sanctions Enforcement and Compliance - April 30th - May 1st, Washington, DC

With unprecedented change and intensifying enforcement, now is the time to ensure your team is prepared for what’s ahead. Ensure that you don’t miss out on critical U.S. and international economic sanctions updates and the...more

BakerHostetler

Requiem for Task Force KleptoCapture: The Future of Russia Sanctions Enforcement

BakerHostetler on

On February 5, 2025, the new Attorney General announced the disbanding of Task Force KleptoCapture, which was launched in March 2022 to enforce the sweeping portfolio of sanctions against Russia. KleptoCapture was part of an...more

Akin Gump Strauss Hauer & Feld LLP

National Security Presidential Memorandum/NSPM-2 (Trump EO Tracker)

Imposes maximum pressure on the Iranian regime to end its nuclear threat, curtail its ballistic missile program, and stop its support for terrorist groups. Relevant Secretaries are required to impose and enforce sanctions,...more

Hinch Newman LLP

DOJ Issues Rule Addressing Threat Posed by Foreign Adversaries’ Access to Americans’ Sensitive Personal Data

Hinch Newman LLP on

On Friday, December 27, 2024, the Justice Department issued a final rule to address “urgent national security risks posed by access to U.S. sensitive personal and government-related data from countries of concern and covered...more

Conyers

Navigating International Sanctions: Impact of the Ukraine War on Bermuda

Conyers on

When Russia invaded Ukraine on 22 February 2022 most Bermudian residents did not think it would have much impact to the island. However as both an overseas territory of the United Kingdom and as an international finance...more

Akin Gump Strauss Hauer & Feld LLP

CryptoLink - November 2024 Updates

CryptoLink is a compilation of news stories published by outside organizations. Akin aggregates the stories, but the information contained in them does not necessarily represent the beliefs or opinions of the firm. Akin's...more

Bass, Berry & Sims PLC

German Company Pays $14.55 Million to Settle Violations of U.S. Sanctions on Iran

Bass, Berry & Sims PLC on

Key Points: - Long-arm of U.S. sanctions jurisdiction reaches conduct by European company. - Violation involved shipment to Iran from Australia, a close U.S. ally. On December 3, the Treasury Department’s Office of...more

Buchalter

Expanded Export Controls and Sanctions Require Heightened Compliance for All Industries

Buchalter on

A Changed Regulatory Environment – Companies who think that U.S. export controls and sanctions do not apply to their products and channels of trade should reassess that position. As an example, approximately US$1.1 billion in...more

American Conference Institute (ACI)

FCPA, Export Controls, and Sanctions Enforcement: Adjusting Compliance Strategies for the New Normal

As the interplay between export controls, trade sanctions, and anticorruption enforcement continues to intensify, multinational companies must remain vigilant in ensuring that their compliance programs address the many...more

King & Spalding

Ten-Year Statute of Limitations for Sanctions Violations Update

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As discussed in our May 7, 2024 alert, on April 24, 2024, President Biden signed into law a foreign military support package (i.e., H.R. 815), which included a provision doubling the statute of limitations (“SOL”) from five...more

Paul Hastings LLP

Statute of Limitations for IEEPA and TWEA Violations Extended to 10 Years, and Additional Sanctions Developments

Paul Hastings LLP on

Recent legislation, H.R. 815, the National Security Supplemental (“the Act”) – further explained by guidance issued by the U.S. Department of the Treasury Office of Foreign Assets Control (“OFAC”) on July 22, 2024 – has...more

Arnall Golden Gregory LLP

Q&A With Allison Raley: Defending Against Government Investigations

Q: What are the primary areas of focus in your practice related to government investigations? A: My practice primarily focuses on defense against enforcement actions brought by regulatory bodies such as the Office of Foreign...more

Sheppard Mullin Richter & Hampton LLP

Federal Reserve Board Issues Cease and Desist Order Against Banking-As-A-Service Provider

On June 14, the Federal Reserve Board (Fed) released a cease and desist order against an Arkansas-based banking-as-a-service (BaaS) provider for compliance and risk management failures. As part of the order, the bank is...more

Snell & Wilmer

United States Government Doubles Statute of Limitations for Sanctions Violations

Snell & Wilmer on

Shrouded within the supplemental emergency appropriations bill for Israel, Ukraine, and Taiwan, the 21st Century Peace through Strength Act passed by Congress and signed into law significantly increases the statute of...more

NAVEX

Sanctions are the “New” FCPA – How this Era of Enforcement Shapes Third-Party Risk Management

NAVEX on

In the summer of 2022, Deputy Attorney General Lisa Monaco – a veteran prosecutor and currently number two at the helm of the U.S. Department of Justice (DOJ) – began to describe the enforcement of sanctions regulations as...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

Adams & Reese

International Compliance Digest – May 2024

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May saw the long-awaited release of the USTR’s Section 301 review. USTR confirmed that the Trump-era tariffs will remain in place, and raised those tariffs by another $18 billion on manufacturing, critical minerals, solar...more

Sheppard Mullin Richter & Hampton LLP

Say SoL Long to Short Limits: Doubling Down on the Sanctions Statute of Limitations

Effective April 24, the statute of limitations (“SoL”) under the International Emergency Economic Powers Act (“IEEPA”) and the Trading with the Enemy Act (“TWEA”) has been extended from five to ten years. It would have been...more

Adams & Reese

International Compliance Digest – April 2024

Adams & Reese on

April was another month of robust trade actions aimed at foreign goods, export compliance, and heightened enforcement powers. DHS issued an enhanced strategy policy on the textile industry with a focus on de minimis...more

Womble Bond Dickinson

DOJ Enhancing Its Sanctions Toolkit

Womble Bond Dickinson on

President Biden recently signed a foreign aid bill that will have significant implications for United States sanctions enforcement, specifically Section 206 of the International Emergency Economic Powers Act (50 U.S.C. 1705)...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

A&O Shearman

U.S. sanctions enforcement in the virtual currency space - USD 1 billion and counting...

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Beginning in 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has increasingly focused its enforcement activity on entities operating in the virtual currency space, illustrating a trend that...more

Morrison & Foerster LLP

UK Sanctions Year in Review 2023

2023 was another significant year for UK sanctions. The UK government has continued to implement new sanctions against Russia in response to its illegal war in Ukraine, including through new designations, broadened financial...more

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