On November 13, 2024, the U.S. Department of the Treasury’s (“Treasury’s”) Office of Foreign Assets Control (“OFAC”) updated its FAQs for insurers in a long-awaited move to modernize its published sanctions compliance guidance for the insurance industry. None of the industry-specific FAQs had been updated since January 2015, and many had not been amended in
Dj Wolff
David (Dj) Wolff is the co-chair of Crowell & Moring’s International Trade Group and a director with C&M International, the firm's trade policy affiliate.
At Crowell & Moring, he serves on the steering committee for the International Trade Group, where his practice focuses on all aspects of compliance with U.S. economic sanctions, including day-to-day compliance guidance, developing compliance programs, responding to government inquiries, conducting internal investigations, and representation during civil and criminal enforcement proceedings. Dj works regularly with non-U.S. clients, both in Europe and Asia, to evaluate the jurisdictional reach of U.S. sanction authorities to their global operations, identify and manage the potential conflict of laws that can result from that reach, as well as to support client’s design, implementation, and evaluation of a corresponding risk-based sanctions compliance program. Dj also regularly leads teams in diligence efforts on trade and related regulatory areas on behalf of his U.S. and non-U.S. clients in the M&A arena, having successfully closed more than 30 deals with an aggregate valuation of several billion dollars over the last 18 months.
Dj is ranked by Chambers USA in International Trade: Export Controls & Economic Sanctions. He has previously been recognized by Law360 as a Rising Star in International Trade (2020), by The National Law Journal as a "DC Rising Star" (2019), by Who’s Who Legal: Investigations as a "Future Leader" (2018 and 2019), Acritas Star as an Acritas Stars Independently Rated Lawyers (2019), by Global Investigations Review as one of the "40 under 40" in Investigations internationally (2017), and WorldECR as one of the five finalists for the WorldECR Young Practitioner of the Year award (2016).
OFSI Granted Greater Sanctions Monitoring and Enforcement Powers
The UK Government has passed new amending sanctions regulations which grants its financial sanctions regulator – the Office of Financial Sanctions Implementation (“OFSI”) – greater intelligence gathering and enforcement powers, and enables OFSI to deal with licensing applications more efficiently.
The majority of the amendments introduced by The Sanctions (EU Exit) (Miscellaneous…
Client Alert: New BIS Guidance Continues Trend of Enhanced EAR Compliance Expectations for Financial Institutions
In new guidance published on October 9, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued recommendations about its expectations for financial institutions in complying with U.S. export control obligations.
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Meet OTSI: New UK Trade Sanctions Enforcement Agency Launches
From Thursday October 10, 2024, the UK has an additional new sanctions regulator following the official launch of the Office of Trade Sanctions Implementation (“OTSI”). First announced in December 2023, its establishment was confirmed last month with the publication of The Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024 (the “Regulations). …
OFAC Extends Recordkeeping Requirements from 5 to 10 Years Through Interim Final Rule
On September 11, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced that it is seeking comments on a new interim final rule amending OFAC’s Reporting, Procedures and Penalties Regulations to extend recordkeeping requirements from five to ten years. While OFAC is seeking comments within 30 days, the interim final rule…
OFAC, State Department, and BIS Expand Russian/Belarusian Sanctions
On August 23rd, 2024, the U.S. Treasury’s Office of Foreign Assets Control (OFAC), the U.S. Department of State (State), and the Commerce Department’s Bureau of Industry and Security (BIS) acted against Russia’s international supply chains.
OFAC and State collectively sanctioned nearly 400 individuals and entities. Of note, this included a substantial focus on…
OFAC Publishes Guidance on Extended Statute of Limitations
On July 22, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) released guidance (“Guidance”) on how it will implement the new authority it was granted in the April 24, 2024 National Security Supplemental (“the Act”). The Act extended the statute of limitations for civil, criminal, and forfeiture violations of sanctions…
EU Implements Long-Awaited “14th Round” of Sanctions Against Russia, Further Targeting Circumvention, LNG and the Transportation Sector
An overview on new Russian sanctions and export controls issued by the European Union, focusing on anti-circumvention measures and the Russian financial, military, and LNG industries.
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Pressure Rising: New U.S. and UK Sanctions and Export Controls Increase Risks for Lingering Russia Exposure, Indirect Evasion in the Supply Chain, and IT Support for Russia Operations
An overview on new Russian sanctions and export controls issued by the U.S. (OFAC and BIS) and the UK focusing on the Russian financial, military, and LNG industries.
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Global Trade Talks: Forced Labor – Mitigating Risk in Auto Industry and Other Sectors
Global Trade Talks is a podcast that shares brief perspectives on key global issues on international trade, current events, business, law, and public policy as they impact our lives. In this session, hosts and International Trade Practice Leaders Nicole Simonian and Dj Wolff talk with Crowell lawyers David Stepp and Simeon Yerokun about Uyghur Forced…