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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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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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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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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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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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Notwithstanding the robust economic sanctions imposed on Russia and Belarus since February 2022 by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), and export controls by…
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Many businesses are of the impression that as long as their internal trade compliance controls include screening against the U.S. Department of the Treasury’s Office of Foreign Assets Control’s (“OFAC”)…
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As of March 27, 2023, the Russian Federation requires all western businesses seeking to divest from the country to make a direct donation to the Russian state. This leaves western…
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With one full year gone by since Russia invaded Ukraine, a lot has been written in the history books of U.S. economic sanctions and export controls. Marking this first anniversary,…
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A new strike force is out, and it’s not a movie or video game (sorry Marvel fans). On February 16, 2023, the United States Department of Justice (“DOJ”) and Department…
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