On July 20, the Office of Foreign Assets Control announced a $2 million penalty against ExxonMobil for violations related to eight documents, a contract extension and seven “Completion Deeds,” that ExxonMobil subsidiaries executed with the Russian state-owned company Rosneft in May 2014 on which Rosneft’s Chairman, Igor Sechin, was a signatory. That same day, ExxonMobil
U.S. Imposes Sanctions On Venezuelan President And 13 Other Government Officials
On July 31, OFAC designated Venezuelan President Nicolas Maduro as a Specially Designated National (SDN) under the Venezuela Sanctions Program, pursuant to Executive Order (E.O.) 13692.
Earlier, on July 26, OFAC added 13 other top Venezuelan officials to its SDN List. These newly designated individuals are linked with numerous branches and agencies of the Venezuelan
President Trump Signs Substantial Expansion Of Sanctions On Russia, Iran, And North Korea
On August 2, President Trump signed into law the Countering America’s Adversaries Through Sanctions Act of 2017 (CAATSA), which imposes new sanctions on Russia, Iran, and North Korea.
While President Trump noted his view that the legislation was “significantly flawed”, its passage represents the successful culmination of months of Congressional negotiations and its provisions
U.K. Modern Slavery Act (MSA) 2015 – Time for Compliance
Companies are paying increased attention to the Transparency in Supply Chains provision contained in the U.K. MSA, which is aimed at requiring companies to root out modern slavery. Those obligated to comply must prepare and publish a slavery and human trafficking statement for each financial year. 2017 is the first year when all organisations to
Enforcement Actions from BIS and FinCEN
Bureau of Industry and Security (BIS)
- On July 25, BIS entered into a Settlement Agreement with Harold Rinko, doing business as Global Parts Supply of Hallstead, Pennsylvania (also known as Rinko/Global Parts Supply) to settle a charge of one alleged violation of the Export Administration Regulations (EAR). The company was assessed a $100,000 civil penalty
National Security Investigations of Steel and Aluminum Imports Heat Up
In May and June, the U.S. Department of Commerce held hearings and accepted hundreds of public comments for its investigations under section 232 of the Trade Expansion Act of 1962 to determine whether U.S. imports of steel and aluminum threaten national security.
DOC missed its self-imposed deadline of June 30 to release its reports and
Senate’s Russia/Iran Sanctions Bill Faces Opposition in Both House and Trump Administrations
With a pause on Capitol Hill because of the July 4th recess, many are taking stock of the prospects for the Senate passed legislation intended to dramatically expand sanctions on Russia. Specifically, a bipartisan group of Senators reached a compromise to combine several pending Russia-related measures and attach them as an amendment to S.722 – The Countering
Enforcement Actions from BIS, OFAC, and DOJ
Bureau of Industry and Security (BIS)
- On June 8, BIS entered into a Settlement Agreement with Axis Communications, Inc. of Massachusetts to settle charges of 15 alleged violations of the Export Administration Regulations (EAR). The company was assessed a $700,000 civil penalty and directed to conduct an external audit of its export compliance program by
Commerce Probes Impact of Steel, Aluminum Imports on National Security
STEEL
A Federal Register Notice published on April 26 provided additional information to industry on the Department of Commerce’s investigation of steel imports and U.S. national security.
- For more detail on the April 21 Presidential Memorandum directing the investigation, please see Crowell’s Client Alert.
We learned a three-hour public hearing will be held on
Recap and Analysis of May 24 Steel Import Investigation Hearing
Commerce Recommendation Expected By End Of June
The Department of Commerce held a public hearing on its Section 232 National Security Investigation of Imports of Steel on May 24. The hearing was chaired by Commerce Secretary Wilbur Ross, who stayed for the majority of the 37 witnesses’ remarks. The balance of the panel included representatives