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Adams and Reese LLP

International Compliance Digest – August 2024

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August was another robust month in international trade that further signifies the need for corporations to invest in effective compliance programs. For starters, the DOJ unveiled a new program that incentivizes corporate...more

BakerHostetler

Current State of U.S. Economic Sanctions Imposed in Response to Russia’s Invasion of Ukraine - August 2024 #2

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In its continuing 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...more

Locke Lord LLP

OFAC Releases Initiatives to Enhance ‎Public Guidance on ‎Sanctions Implementation

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On August 21, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a series of new initiatives to assist the public to better understand sanctions and the role of the private sector...more

Adams and Reese LLP

International Compliance Digest – July 2024

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July was a big month for compliance with a handful of reports and recommendations on due diligence and best practices concerning forced labor, export controls, sanctions from DHS, BIS, and OFAC. The below updates also...more

McGuireWoods LLP

OFAC Enforcement Action Targets Non-U.S. Business Purchasing Services From North Korean Firm

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On June 26, Treasury’s Office of Foreign Assets Control (OFAC) announced the settlement of an enforcement action against an Italian animation company that violated OFAC’s sanctions on North Korea. The enforcement action...more

Hogan Lovells

Significant new measures against Russia issued by US Departments of Treasury, State, and Commerce

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On 12 June 2024, the US Departments of Treasury, State, and Commerce imposed new restrictions targeting Russia, including: (i) restricting the provision of certain information technology and software services to Russia...more

Adams and Reese LLP

International Compliance Digest - June 2024

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Sanctions and export controls were the top items of interest in June. On the compliance side, OFAC and the BIS announced new sanctions and export controls on Russia and Belarus. The new measures target individuals and...more

Blank Rome LLP

New Russia Sanctions Target IT Services, Enterprise Management Software, and Foreign Financial Transactions

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) and the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) recently issued a significant new round of sanctions and export...more

Orrick, Herrington & Sutcliffe LLP

Sweeping New U.S. Sanctions and Export Controls Intensify Pressure on Russia and Belarus As Russia Transitions to a Full War...

The United States has substantially expanded economic sanctions and export controls targeting Russia and Belarus, imposing new restrictions that could have a major impact on companies with business activities in or relating...more

Wilson Sonsini Goodrich & Rosati

Biden Administration Further Expands Export Controls and Sanctions on Russia and Belarus

On June 12, 2024, ahead of the 2024 G7 Summit, the Biden administration introduced new export controls and sanctions on Russia and Belarus in an effort to limit Russia’s ability to continue its war efforts against Ukraine....more

Sheppard Mullin Richter & Hampton LLP

Now Including the Kitchen Sink: Expansion of Export Controls on Russia Adds Restrictions on Low-Level Items and Software

Last year, we published an update on BIS’s foray into prohibiting EAR99 items for export to Russia and Belarus. We noted (somewhat in jest) that kitchen sinks may one day be added. Well, that day has come. Stainless steel...more

Cadwalader, Wickersham & Taft LLP

US and UK Issue New Round of Russia-Related Sanctions in Connection with G7 Summit

During the week of the G7 Summit, both the U.S. and UK issued a new round of Russia-related sanctions as Russia’s invasion of Ukraine enters its 28th month. On June 12, 2024, the U.S. Department of the Treasury’s Office of...more

Dechert LLP

U.S. Sanctions Russian Financial Infrastructure

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On the eve of the 2024 Group of Seven (G7) Leaders’ Summit, the United States imposed new sanctions and export control measures against Russia further targeting sanctions evaders and, for the first time, the Russian...more

White & Case LLP

The Shadow Financial System

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The concept of the shadow financial system rose to international prominence in the aftermath of the 9/11 terrorist attacks. In an interview with a Pakistani newspaper a month later, Osama bin Laden stated that Al Qaeda were...more

ArentFox Schiff

US Government Throws “Kitchen Sink” Export Controls at Russia, Plus Sweeping EAR99 Software Controls, and IT and Software Services...

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Three US agencies – the US Department of Commerce, Bureau of Industry and Security (BIS), the US Department of the Treasury, Office of Foreign Assets Control (OFAC), and the US Department of State – took new actions on June...more

Seward & Kissel LLP

OFAC Issues New Wave of Russia Sanctions Expanding Secondary Sanctions Risk for Foreign Financial Institutions

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On June 12, 2024, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), in coordination with the U.S. Department of State, announced a new wave of Russia sanctions that significantly expand...more

Fenwick & West LLP

U.S. Imposes Sweeping New Sanctions and Export Controls on Russia and Belarus, including on Certain Software and Related Services

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Citing Russia’s “transition to a full war economy,” the United States imposed sweeping new sanctions and export controls on Russia and Belarus today, including companies and individuals that continue to supply Russia’s...more

Pillsbury - Global Trade & Sanctions Law

Treasury Amends the Cuban Assets Control Regulations to Support Cuban Citizens and Independent Private Sector Entrepreneurs

On May 28, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) amended the Cuban Assets Control Regulations (CACR) to better implement the Biden-Harris Administration’s policy aimed at...more

Wiley Rein LLP

Treasury Department Amends Cuba Sanctions, Expands Access to Internet and Financial Services for Cuban Nationals

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On May 28, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced amendments to the Cuban Assets Control Regulations (CACR), which expand authorizations for certain financial and...more

The Volkov Law Group

Supply Chain and Sanctions Compliance (Part III of IV)

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While OFAC’s enforcement actions and guidance points to important steps exporters must take when relying on third-party distributors and other intermediaries, the “reason to know” and affirmative obligations to monitor resale...more

Hogan Lovells

Statute of limitations extended for violations of U.S. sanctions

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Congress has doubled the statute of limitations for violations of most U.S. sanctions programs administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control.  Companies should be aware of the...more

Fenwick & West LLP

Sanctions Violations: New 10-Year Statute of Limitations

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On April 24, 2024, President Biden signed into law an emergency supplemental appropriations law, H.R. 815 (Public Law 118-50), that provides substantial military aid to Ukraine, Israel, and Taiwan and could force the sale of...more

Morrison & Foerster LLP

War Aid and Sanctions: National Security Act Includes Significant New Sanctions Authorities

On April 24, 2024, President Biden signed into law a long-debated $98 billion foreign aid and national security legislative package (the “Act”) providing funds for Israel, Taiwan, and Ukraine, and authorizing new sanctions...more

Orrick, Herrington & Sutcliffe LLP

OFAC Signals Willingness to Use FinCEN Whistleblower Incentive Program for Sanctions Violations

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has announced two enforcement actions this year. Both reference the Financial Crimes Enforcement Network's (FinCEN) whistleblower program,...more

Foley Hoag LLP - White Collar Law &...

Enforcement of U.S. Trade Sanctions and Export Controls in 2023 and What to Expect In 2024

This is the tenth in our 2024 Year in Preview series examining important trends in white collar law and investigations in the coming year. Our previous post, "Health Care Fraud Enforcement in 2024," can be found here....more

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