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
The centrality of international trade laws in the development and execution of U.S. foreign policy has never been more evident than in 2022. Companies that have not invested in international trade compliance programs are...more
Uphold is a California-based money service business. Uphold agreed to pay OFAC $72,230 to resolve multiple sanctions program violations....more
2022 was an unprecedented year for U.S. sanctions and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). While the sweeping new U.S. sanctions imposed against Russia and Belarus in unparalleled...more
The U.S. Government is continuing its frequent and highly visible use of denied party lists as an important tool in administering the export control laws. Each of the Bureau of Industry and Security (BIS), the Office of...more
The US Treasury Department has released its 2021 Sanctions Review (the “Review”), which describes the US sanctions framework and the agency’s future sanctions priorities. The Review reflects on the evolution over two decades...more
Despite a shift in the sanction landscape, it will take time for enforcement activity to catch up. As a result, organizations should regularly examine their exposure with business partners around the globe and consult with...more
Turning to the business of exports from the United States, the next section is a must-read for any company doing business in the United States or from the United States. Or for that matter, any company competing with affected...more
Recognizing that COVID-19 is further straining humanitarian needs in sanctioned countries and complicating compliance with economic sanctions, and perhaps also in response to reports that US sanctions are hindering COVID-19...more
Report on Supply Chain Compliance 3, no. 7 (April 2020) The United States Department of the Treasury’s Office of Foreign Assets Control has stayed busy during the coronavirus outbreak. The office made several new additions...more
Huawei Charged in Racketeering Conspiracy and Conspiracy to Steal Trade Secrets; Temporary General License Extended – On February 13, 2020, Huawei Technologies Co. Ltd. (Huawei) and two of its U.S. subsidiaries were...more
Report on Supply Chain Compliance 3, no. 2 (January 23, 2020) - The new year has brought new sanctions actions by the United States Department of the Treasury’s Office of Foreign Asset Control and the U.S. Department of...more
The new Iran sanctions imposed by the Trump Administration are not the only recent sanctions actions of note. Congress has also shown its willingness to use sanctions as a foreign policy tool, with certain sanctions...more
The U.S. Treasury Department, Office of Foreign Assets Control (OFAC), the main U.S. government body that administers U.S. economic sanctions and embargoes, continues to be busy. In September 2019 alone, OFAC has announced...more
Bank Secrecy Act/anti-money laundering (BSA/AML) and sanctions matters continue to be a core focus of regulators, law enforcement agencies, policymakers and Congress, and the story of the Obama and Trump Administrations on...more
In this quarter, OFAC lifted sanctions on Rusal and other companies following divestment by Oleg Deripaska. Meanwhile, as Venezuela descends into economic and political crisis, the US targeted PdVSA and others to hasten...more
With Brexit looming, the UK's autonomous sanctions policy is slowly taking shape. This month saw the publication of regulations setting out the post-Brexit UK sanctions regimes for Iran, Burma and Venezuela, which will come...more
In 2018, the United States continued to expand its sanctions programs and increase enforcement. While President Donald Trump’s decision to re-impose nuclear-related sanctions on Iran has perhaps drawn the most attention, key...more
TABLE OF CONTENTS: Executive Summary - Developments and Trends in Policy and Enforcement - US Department of the Treasury - The Office of Foreign Assets Control - Treasury's Financial Crimes Enforcement Network -...more
Happy new year everyone. The government is shut down, but there has already been a flurry of activity in 2019 on the economic sanctions and embargoes front. Here is a summary of where we stand on various sanctions regimes....more
International sanctions are a major compliance challenge for companies worldwide. The regulatory risks associated with economic sanctions, asset-freezing measures and trade embargoes are not new, but they continue to grow in...more
ANTICORRUPTION DEVELOPMENTS – Canadian Mining Company Settles with SEC over FCPA Charges – On March 26, Kinross Gold Corporation settled with the Securities and Exchange Commission (SEC) over its alleged failure to...more
ANTICORRUPTION DEVELOPMENTS - Mega International Commercial Bank Co. Ltd. Fined $29 Million - On January 17, 2018, the U.S. Federal Reserve Board assessed Taiwan based bank Mega International Commercial Bank Co. Ltd. a...more