News & Analysis as of

SDN List

Foley & Lardner LLP

Fourth Circuit Holds No Article III Standing Where No Third-Party Viewed Inaccurate Information

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On September 11, 2024, the Fourth Circuit Court of Appeals held that there is no publication to a third party — and therefore no Article III standing under the Fair Credit Reporting Act (FCRA) — where the recipient of a...more

Locke Lord LLP

OFAC Amends Cuban Assets Control Regulations and Issues New FAQs for U-Turn Transactions

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On August 27, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced amendments to two key FAQs (FAQs 736 and 757) concerning the Cuban Assets Control Regulations (“CACR”). These FAQs...more

Husch Blackwell LLP

The Justice Insiders Podcast - The Ever-Expanding Net: Corporate Compliance in an Era of Increasing Trade Sanctions and...

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Host Gregg N. Sofer welcomes Husch Blackwell partner Grant Leach to the program to discuss the burgeoning set of requirements and restrictions placed on U.S. businesses in connection with trade law. Gregg and Grant identify...more

WilmerHale

China, the United States, and the Rivalry Over the Imposition of Unilateral Trade Sanctions

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China has long maintained that trade sanctions imposed unilaterally by one or more countries outside the scope of the United Nations Security Council, where China enjoys veto power as one of the five permanent members, are...more

Dorsey & Whitney LLP

Biden Administration Again Expands Sanctions on Russia and Its Third Party Supporters

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As Russia continues its war against Ukraine and Ukraine has itself recently opened a new front by capturing Russian territory in its Kursk region, the United States announced on August 23 its latest tranche of sanctions...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 Extends and Issues General Licenses Involving Russian Tax and Civil Aviation Safety

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The U.S. Department of the Treasury’s Office of Foreign Asset Control ‎‎(“OFAC”) on (i) July 10, 2024, extended General License (“GL”) 13J (“Authorizing Certain Administrative Transactions Prohibited by Directive 4 under...more

The Volkov Law Group

U.S. Sanctions Update as of April 2024

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U.S. Persons prohibited from transactions with anyone on the OFAC SDN List without a license, regardless of country. Includes entities owned in excess of 50-percent by one or more SDNs (33-percent for select Russian...more

King & Spalding

The U.S. Departments of Commerce and State Issue Proposed Rules Expanding Controls on Military and Security-Related Services, End...

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To curtail U.S. persons from supporting the efforts of adversarial regimes, such as China and Russia, in advancing their military and intelligence capabilities, the U.S. is proposing a significant expansion of export control...more

Seyfarth Shaw LLP

BIS Publishes Interim Final Rule on “Standards-Related Activities"

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On July 18, 2024, the U.S. Dept. of Commerce, Bureau of Industry and Security (BIS) published a new interim final rule (the “Interim Final Rule”) entitled “Standards-Related Activities and the Export Administration...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

The Volkov Law Group

OFAC Amends SDN and SSI List Entries to Incorporate Secondary Sanctions Warnings

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On July 3, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced that it had amended entries for a multitude of entities sanctioned under the Treasury’s Russian Harmful Foreign...more

Latham & Watkins LLP

US Treasury Department Issues Notice of Proposed Rulemaking on Implementation of Outbound Investment: 5 Key Takeaways

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The proposed regulations would implement President Biden’s Executive Order that restricts certain outbound investments from the US. On June 21, 2024, the US Department of the Treasury (Treasury) issued a Notice of Proposed...more

Akin Gump Strauss Hauer & Feld LLP

Treasury Issues Proposed Regulations Prohibiting Certain US Investment in Chinese Technology Companies

The Notice of Proposed Rulemaking (NPRM or the Proposed Rule), issued by Treasury on June 21, 2024, would implement President Biden’s August 9, 2023, Executive Order on outbound investment, which addresses concerns related to...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

WilmerHale

New Multi-Jurisdictional Sanctions Continue to Target Broad Scope of Activities With Russia

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In conjunction with the Group of Seven (G7) leaders meeting in Italy earlier this month, key jurisdictions issued the latest in a series of coordinated economic restrictions on Russia in light of its invasion of Ukraine in...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

Faegre Drinker Biddle & Reath LLP

Additional Export Restrictions to Russia and Belarus: BIS Announces Additional Export Sanctions Against Russia and Belarus and...

On June 12, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced several significant additional export control restrictions and related actions against Russia as a response to continued...more

Fenwick & West LLP

BIS Prohibits Transactions with Kaspersky Lab in Its First Final ICTS Determination

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On June 20, 2024, the Bureau of Industry and Security (BIS) issued its first Information and Communications Technology and Services (ICTS) Final Determination pursuant to Executive Order 13873 and 15 C.F.R. Part 7,...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

Wiley Rein LLP

New U.S. Sanctions and Export Controls on Russia Target Foreign Financial Institutions, Business Software, Critical Industries

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The Biden Administration’s recent expansion of sanctions and export controls to counter Russian aggression will impact non-U.S. financial institutions and increase compliance risks for the business software sector and other...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

K2 Integrity

Sanctions Against Russia: U.S. Increases Secondary Sanctions Risks for Foreign Financial Institutions, Expands Sanctions and...

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On 12 June 2024, 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) issued new measures to further isolate Russia’s...more

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