On July 27, 2023, the Department of Commerce’s Bureau of Industry and Security (BIS) announced that U.S. persons reporting boycott-related requests to its Office of Antiboycott Compliance (OAC) must now also disclose the identity of the specific party that made the request. Previously, U.S. persons were required to disclose when they had received a boycott-related
Export Controls & Economic Sanctions
The Government Continues to Prioritize Export Control and Sanctions Enforcement Highlighted in New Tri-Seal Compliance Note and Cooperative Agreement Between BIS and OFAC.
On Wednesday, July 26, the Departments of Commerce, Treasury, and Justice issued a Tri Seal Compliance Note detailing the voluntary self-disclosure of potential violations for export controls, sanctions, and other national security laws. The Compliance Note highlights the new changes made to the Department of Justice’s voluntary self-disclosure policy. The Note also provided an overview…
Podcast: The Latest on Russia Sanctions
Check out the latest episode of The Justice Insiders—a podcast hosted by Husch Blackwell partner Gregg Sofer—where we explore the intersection of international trade law and government investigations and enforcement, particularly in connection with Russia.
I previously appeared on Gregg’s podcast during the first quarter of 2022, and we pick up that…
OFAC and U.S. Department of State Issue New Sanctions and Designates More Than 300 Russian Federation Individuals and Companies Aiding Russia’s War Efforts
On Friday, May 19, 2023, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) announced the addition of more than 300 Russian Federation individuals and companies as well as other individuals and companies alleged to be aiding Russia’s war efforts to the Specially Designated Nationals and Blocked Persons (“SDN”) List. Simultaneously, the U.S.
BIS Implements Additional Export Controls and Entity List Additions Targeting Russia to Align with Allies and Partners
On May 19, 2023, the Department of Commerce’s Bureau of Industry and Security (“BIS”) announced new export controls and Entity List additions during President Biden’s G7 visit in Japan. In conjunction with the G7 meetings, BIS stated these new restrictions are designed to better align U.S. controls with those of its partner and ally countries…
BIS Levies Record Penalty for Export Control Violations related to Huawei Shipments
Recently, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) announced the issuance of a $300 million penalty against Seagate Technology LLC and its Singapore affiliate, Seagate Singapore International Headquarters Pte. Ltd., (collectively, “Seagate”) to resolve apparent violations of the Huawei foreign direct product rule (the “Huawei FDP Rule”). BIS stated this case…
DOJ Continues Pursuit of Export Control Violations
Yesterday, our team published a client alert exploring recent statements made by Deputy Attorney General Lisa Monaco in connection with the Department of Justice’s continued efforts to investigate and prosecute individuals for violating economic sanctions, export controls, and other similar economic crimes. The statements—made at an American Bar Association event last week—demonstrate that export controls continue to rank highly among DOJ’s priorities.
BIS Issues New Export Controls and Entity List Additions Targeting Russia on One-Year Anniversary of Invasion
The Department of Commerce’s Bureau of Industry and Security (“BIS”) announced today new export controls and Entity List additions designed to further restrict Russia’s ability to maintain its continued war against Ukraine. The Biden Administration’s measures come on the one-year anniversary of Russia’s invasion of Ukraine and the first announcement by several Western countries, including…
OFAC Issues Sweeping Sanctions to Mark One-Year Anniversary of Russia’s Invasion of Ukraine
On Friday, February 24, 2023, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued new sanctions against individuals and entities operating in Russia and against those assisting with Russia’s war efforts in Ukraine. In combination with OFAC’s additional sanctions, BIS also implemented additional export control measures and added 86 identified supporters of the…
Export Control Violations Result in Significant Monetary Penalties and Continuing Compliance Training Obligations
In a recent order, the Department of Commerce’s Bureau of Industry and Security (“BIS”) revoked the export privileges for Obaidullah Sayed, an Illinois resident. Sayed was convicted of conspiring to export computers, computer systems, and other related equipment to the Pakistan Atomic Energy Commission without a license. Sayed was sentenced to one year and…