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On November 26, the U.S. Court of Appeals for the Fifth Circuit reversed and remanded a decision by the district court regarding the Office of Foreign Assets Control’s (OFAC) designation of a virtual currency mixer software...more
On November 26, 2024, the Fifth Circuit issued an opinion in Van Loon v. Department of the Treasury that invalidated economic sanctions imposed by the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) on...more
The Proposed Rule imposes substantial new reporting, diligence, and compliance obligations for companies in the automotive supply chain - On September 26, 2024, the U.S. Department of Commerce’s Bureau of Industry and...more
The U.S. Commerce Department is soliciting comments on a proposed rule to prohibit importing and selling Vehicle Connectivity System hardware and software designed, developed, manufactured, or supplied by persons owned by,...more
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
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
The U.S. Department of Commerce's Office of Information and Communications Technology and Services (OICTS) within the Bureau of Industry and Security (BIS) issued a Final Determination on June 20, 2024, pursuant to Executive...more
In the Biden Administration’s continuing effort to reduce the risk of cybersecurity spyware from foreign adversaries, including Russia, the United States Department of Commerce (Commerce) issued a final rule (Rule) on June...more
On June 20, 2024, the Department of Commerce's Bureau of Industry and Security (BIS) issued a Final Determination (“Determination”) prohibiting Kaspersky Lab, Inc.—the US subsidiary of the Russia-based antivirus software and...more
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
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
On June 12, 2024, the United States took several hard-hitting sanctions- and export control-related actions intended to intensify pressure on the Russian government and hamper Russia’s ability to continue to support its war...more
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
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
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
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
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
Throughout December, the United States, European Union, and United Kingdom adopted a series of new sanctions packages against Russia that are expansive and multilayered and pose additional compliance challenges. The new...more
Ransomware has become a major threat to businesses across the world as cyber-attacks are becoming increasingly sophisticated, resulting in devastating financial damage for companies that fall victim. Not only are important...more
On April 6, 2023, Microsoft Corporation (“Microsoft”) agreed to pay $3.3 million to the Department of Commerce’s Bureau of Industry and Security (“BIS”) and the Department of the Treasury’s Office of Foreign Assets Control...more
On April 6, 2023, the Department of Treasury Office of Foreign Assets Control (“OFAC”) and the Department of Commerce Bureau of Industry and Security (“BIS”) announced a settlement with Microsoft Corporation (“Microsoft”) and...more
Microsoft’s remedial steps provide important best-practices for companies facing similar risk factors in the global economy, especially for global software companies that rely on Internet-based operations....more
OFAC announced only one settlement in the first three months of 2023. Given its ongoing role in the implementation and enforcement of Russia Sanctions, OFAC’s enforcement record so far is completely understandable. The...more
U.S. Customs and Border Protection (CBP) held The Forced Labor Technical Expo: Tools for Supply Chain Transparency from March 14-15, 2023, which involved members of the U.S. importing community, partner government agencies,...more
On March 30, 2023, Wells Fargo agreed to remit $30,000,000 to settle its penalty liability across multiple sanctions programs with U.S. Department of the Treasury’s Office of Foreign Asset Controls. Across several years,...more