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
Jackie Schaeffer
BIS Announces Further Updates to OEE’s Voluntary Self-Disclosure Process for Minor Violations
By Jeffrey L. Snyder, Jackie Schaeffer & Dilan Wickrema on
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
By Jackie Schaeffer, Jana del-Cerro & Andrew J. Schlegel on
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
By Andrew J. Schlegel, Jeffrey L. Snyder, Sophie Davis & Jackie Schaeffer on
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…