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On October 7, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) confirmed some rather significant changes to the OFAC unblocking procedures for blocked property, which…
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One concern I hear a lot from businesses outside the United States is regarding so-called “secondary sanctions” of the United States (“U.S.”), especially since the rapid expansion of the U.S.…
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For better or worse, the U.S. Supreme Court has overruled Chevron v. Natural Resources Defense Council (“Chevron”), which for the last 40 years has provided many U.S. government agencies with significant…
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When President Biden signed into law the April 24, 2024 National Security Package (H.R. 815), media outlets predominately focused their coverage on the long awaited United States (“US”) aid for…
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Upon its December 23, 2021 enactment, the Uyghur Forced Labor Prevention Act (“UFLPA”), Public Law No. 117-78, directed the United States government’s interagency Forced Labor Enforcement Task Force (“FLETF”) to…
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On March 21, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) significantly expanded its end-user restrictions under the Export Administration Regulations (“EAR”), 15 C.F.R. Part 744,…
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The U.S. Department of the Treasury’s Office of Foreign Assets Control’s (“OFAC”) last civil enforcement action for 2023 involved insurance company Privilege Underwriters Reciprocal Exchange (“PURE”), and was a stark reminder of…
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On the eve of the second anniversary of Russia’s full-scale war against Ukraine, February 23, 2024, and also in response to the on February 16, 2024 death of opposition figure…
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One of several lists administered by the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) is the lesser-known Unverified List (“UVL”). While persons may be added to BIS’s…
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Economic sanctions, especially those related to Russia and Iran, routinely make news headlines. However, the underlying legal changes that occur can significantly impact the operations of organizations engaging in cross-border…
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The expansive scope of United States economic sanctions programs—comprised of the laws and regulations administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”)—can have a…
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Banks are increasingly verifying with their exporting clients whether their transactions related to the export of goods—even ordinary consumer goods—had appropriate license authorization from the U.S. Department of Commerce’s Bureau…
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