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Hogan Lovells

U.S. State Department reinstates Cuba Restricted List

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The U.S. Department of State has formally republished the Cuba Restricted List, restoring prohibitions on direct financial transactions with numerous Cuban military, intelligence, and security-linked entities. This move...more

Ropes & Gray LLP

Russia/Ukraine Crisis: U.S. Targets Russia’s Energy Industry

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On January 10, 2025, the United States announced (another) major sanctions package targeting Russia, potentially representing the Biden administration’s last and best effort to strengthen Ukraine’s negotiating position in...more

Mayer Brown

Russia/Ukraine Sanctions Update - Month of September

Mayer Brown on

I.  US SANCTIONS - U.S. Department of the Treasury Acts Against Russian Virtual Currency Exchanges: On September 26, the U.S. Department of the Treasury announced that its Financial Crimes Enforcement Network issued an...more

Lowenstein Sandler LLP

New Prohibitions on Providing SaaS Services to Russia

In line with Group of Seven (G7) efforts to disrupt the Russian military-industrial base’s reliance on foreign IT systems, in June 2024 the U.S. Department of Commerce and the Department of the Treasury jointly issued new...more

Lowenstein Sandler LLP

Trade Matters - Lowenstein Sandler's Global Trade & National Security Newsletter - JULY 12, 2024

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On June 20, the Department of Commerce’s Bureau of Industry and Security (BIS) for the first time banned a software and cybersecurity company using authority provided by June 2023’s “Protecting Americans’ Sensitive Data from...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

BakerHostetler

Key Sanctions Developments During the First Quarter of 2024

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During the first quarter of 2024, there were significant developments in the U.S. sanctions framework. This report summarizes the key developments and provides links to the relevant sources....more

Cooley LLP

Tri-Seal Compliance Note Highlights Broad Reach of US Trade Controls, Obligations of Non-US Persons

Cooley LLP on

On 6 March 2024, the US Department of Commerce, Department of the Treasury and Department of Justice issued a Tri-Seal Compliance Note (compliance note) advising foreign-based companies and individuals to assess their...more

Pillsbury Winthrop Shaw Pittman LLP

Non-U.S. Companies on Alert: U.S. Government Issues Tri-Seal Compliance Note on Global Enforcement

New Tri-Seal Compliance Note highlights sanctions and export control compliance expectations for non-U.S. persons. Three agencies overseeing U.S. trade law compliance provided an overview of where U.S. sanctions and export...more

Mayer Brown

US Agencies’ Tri-Seal Compliance Note Emphasizes Extraterritorial Reach of Sanctions and Export Control Obligations

Mayer Brown on

On March 6, 2024, the US Departments of Commerce (“Commerce”), Treasury (“Treasury”), and Justice (“DOJ”) released their latest Tri-Seal Compliance Note (“Note”), which focuses on the “Obligations of foreign-based persons to...more

A&O Shearman

U.S. Imposes New Russia Sanctions and Export Controls and Warns of Risk of Continued Business with Russia

A&O Shearman on

On February 23, 2024, the United States imposed its largest number of new sanctions and export control designations against Russia to date—targeting over 600 individuals and entities across a wide swath of the Russian economy...more

Lowenstein Sandler LLP

Trade Matters - Lowenstein Sandler's Global Trade & National Security Newsletter - February 14, 2024

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Teradyne, a Massachusetts-based supplier of semiconductor testing equipment, has reportedly pulled $1 billion of manufacturing equipment out of China in 2023 following export controls on advanced computing materials and...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – January 2024 Update

January saw continuing focus on Russia. First, the Commerce Department’s Bureau of Industry and Security (BIS) expanded export controls on certain goods for Russia and Belarus. Second, a U.S.-Israeli citizen was arrested for...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – December 2023 Update

Bass, Berry & Sims PLC on

December saw continuing enforcement actions involving Russia. First, the Treasury Department’s Office of Foreign Assets Control (OFAC) settled investigations into apparent sanctions violations by a New York-based insurance...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – October 2023 Update

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October saw two major enforcement actions involving Russia. First, three individuals were indicted for facilitating the export of controlled U.S.-origin electronics to Russia. Second, the president of a U.S. steel trading...more

WilmerHale

OFSI Encourages Self-Reporting of Sanctions Breaches

WilmerHale on

Companies faced with the decision of whether to voluntarily self-report sanctions breaches to law enforcement or sanctions enforcement agencies in the UK and the US can take some measure of comfort from recent comments made...more

Jones Day

Federal Agencies Highlight Benefits of Self-Disclosure, Emphasize Enforcement of Trade Violations in Tri-Seal Compliance Note

Jones Day on

In a coordinated announcement, federal agencies stress the benefits of voluntarily disclosing potential trade violations while emphasizing increased enforcement....more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – July 2023 Update

Bass, Berry & Sims PLC on

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

Dorsey & Whitney LLP

Executive Order 14105 on Outbound Investment in China and Proposed Rule

Dorsey & Whitney LLP on

On August 9, President Biden issued Executive Order 14105 (“EO 14105”) on Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern. EO 14105 significantly reshapes...more

Husch Blackwell LLP

The Government Continues to Prioritize Export Control and Sanctions Enforcement Highlighted in New Tri-Seal Compliance Note and...

Husch Blackwell LLP on

On Wednesday, July 26, the Departments of Commerce, Treasury, and Justice issued a Tri Seal Compliance Note detailing the voluntary self-disclosure of potential violations for export controls, sanctions, and other national...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

Paul Hastings LLP

DOJ OFAC BIS Joint Compliance Note and Enhanced Coordination Highlights Increased Enforcement Risk

Paul Hastings LLP on

On July 26, 2023, the U.S. Departments of Justice, Treasury, and Commerce issued a joint compliance note (“JCN”) regarding voluntary self-disclosure (“VSD”) policies that apply to potential violations of U.S. sanctions...more

Foley Hoag LLP

DOJ, BIS, and OFAC Issue Tri-Seal Compliance Note Regarding Self-Disclosure of Potential Sanctions Violations

Foley Hoag LLP on

On July 26, 2023, the U.S. Department of Justice’s (“DOJ”) National Security Division (“NSD”), the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”), and the U.S. Department of the Treasury’s Office of...more

Hogan Lovells

U.S. agencies signal reinforced export enforcement collaboration and partnership

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The U.S. Departments of Commerce, Justice and Treasury have issued a “Tri-Seal” Compliance Note regarding national security laws and regulations and the voluntary self-disclosure of potential violations, highlighting...more

Skadden, Arps, Slate, Meagher & Flom LLP

US Authorities Hammer Home the Importance of Self-Disclosing Sanctions and Export Control Violations

On July 26, 2023, the U.S. Department of Justice’s (DOJ’s) National Security Division (NSD), the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), and the U.S. Department of the Treasury’s Office of Foreign...more

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