In issuing the Affiliates Rule with immediate effect, the U.S. Department of Commerce Bureau of Industry and Security (BIS) drastically expanded the number of entities subject to the BIS’ most restrictive export tools by applying the same trade prohibitions to any entities that are owned, directly or indirectly, 50 percent or more by one or
Jackie Schaeffer
Jackie Schaeffer is an associate in Crowell & Moring’s New York office and a member of the firm’s International Trade Group. Jackie focuses her practice on global compliance, regulatory enforcement, investigations, and transactional matters at the intersection of U.S. national security and international trade, including economic sanctions, anti-money laundering (AML), export controls, and the Committee on Foreign Investment in the United States (CFIUS).
Jackie received her J.D. from Stanford Law School where she was a Franke Fellow in Global Business Law. She received her LLM in EU and International Business Law from The University of Vienna School of Law. During law school, she worked at the Estonian Foreign Ministry, clerked for the Honorable Chief Justice of the Supreme Court of the Republic of Rwanda, and worked with the United Nations Independent Commission of Inquiry on Ukraine.
Prior to law school, Jackie was a Coro Fellow in Public Affairs in San Francisco.
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…
BIS Announces Further Updates to OEE’s Voluntary Self-Disclosure Process for Minor Violations
On January 16, 2024, Bureau of Industry and Security (BIS) Assistant Secretary for Export Enforcement Matthew Axelrod announced further updates to the EAR voluntary self-disclosure (VSD) process, all designed to incentivize the prioritization of export control compliance resources of the U.S. Government, industry, and academia.
The Office of Export Enforcement (OEE) released a Memorandum to…
BIS Expands Export Administration Regulations, Adds 13 Entities to Unverified List
On December 19, the Bureau of Industry and Security (“BIS”) added 13 new entities to its Unverified List (“UVL”). All 13 of these entities were added under the destination of the Peoples’ Republic of China (“PRC”) on the basis that BIS was unable to verify their bona fides.
The UVL contains the names and addresses…
Treasury’s OFAC Announces Magnitsky Designations for Two Former Afghan Government Officials
On December 11, the U.S. Department of Treasury (“Treasury”)’s Office of Foreign Assets Control (“OFAC”) announced sanctions against two former Afghan government officials, Mir Rahman Rahmani and his son, Ajmal Rahmani (collectively, “the Rahmanis”), as well as 44 associated entities. These individuals and entities were designated pursuant to Executive Order 13818, which builds upon and…