In Island Industries Inc. v. Sigma Corp., the Ninth Circuit is set to address whether federal district courts have subject matter jurisdiction over customs fraud cases in actions initiated under the qui tam provisions of the False Claims Act (“FCA”). The FCA allows private parties (“relators”) to file suits on behalf of the government
Sanctions/Export Highlights [As of November 03, 2022]
OFAC Guidance: On October 31, 2022, the Office of Foreign Assets Control (“OFAC”) published Frequently Asked Question (“FAQ”) 1094, confirming that Russian crude oil loaded onto a vessel at the port of loading for maritime transport prior to December 5, 2022, is not subject to a to-be-determined oil price cap, provided that the oil
Sanctions/Export Highlights [As of October 20, 2022]
New U.S. and UK Sanctions Partnership: On October 13, 2022, the Office of Foreign Assets Control (“OFAC”) and the UK’s Office of Financial Sanctions Implementation (“OFSI”) announced that they had concluded multi-day meetings in London involving technical exchange of information between the two sanctions authorities. The agencies have decided to enhance OFAC-OFSI cooperation further, including
U.S. Department of Commerce’s Bureau of Industry and Security Strengthens Antiboycott Regulations
On October 7, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) simultaneously published a final rule strengthening the antiboycott regulations in Part 766 of the Export Administration Regulations (EAR) (the “Final Rule”), as well as a memorandum on the new rule’s implementation (the “Final Rule Memo”), issued by the Assistant Secretary