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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Commerce, Treasury, DOJ Publish Tri-Seal Sanctions and Export Control Compliance Note
On March 6, 2024, the Department of Commerce, the Department of the Treasury, and the Department of Justice published a Tri-Seal Compliance Note titled “Obligations of foreign-based persons to comply with U.S. sanctions and export control laws” (the “Note”). The Note stresses that U.S. persons are not the only entities subject to U.S. sanctions and
BIS Publishes FAQs on Export Controls of Semiconductors and Advanced Computing Items
On December 29, 2023, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) published a series of Frequently Asked Questions (FAQs) addressing comments received on the October 13, 2022 interim final rules that amended, and in some cases expanded, U.S. export restrictions on semiconductor manufacturing items and advanced computing items and end uses.
FinCEN Proposes Delaying Some Beneficial Ownership Filing Deadlines and Releases Additional Guidance for Beneficial Ownership Information Reporting
In advance of the impending January 1, 2024 effective date for the U.S. Treasury Department, Financial Crimes Enforcement Network’s (“FinCEN’s”) beneficial ownership information (“BOI”) reporting requirements, FinCEN has proposed an extension of the reporting deadline for some reporting companies, and issued additional guidance regarding BOI reporting requirements, including a Small Entity Compliance Guide, a
Executive Order and Rulemaking on U.S. Outbound Investment
What You Need to Know
- Key takeaway #1 Issuance of Executive Order and Rulemaking: On August 9, 2023, President Biden issued a long-anticipated “Executive Order on Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern” (the “Executive Order”). The Executive Order, which the President issued pursuant to the
State Department Publishes Fact Sheet on AUKUS Trade Authorization Mechanism
On July 10, 2023, the State Department released a Fact Sheet with additional details on the AUKUS Trade Authorization Mechanism (ATAM). ATAM appears likely to operate as a license exemption under the International Traffic in Arms Regulations (ITAR), leveraging the existing ITAR §126.4, to authorize transfers of certain approved categories of defense articles and
China’s Revised Counterespionage Law and Recent Actions Highlight Challenges for U.S. Companies Operating in China
While the Biden’s administration’s recent corporate enforcement actions and initiatives have garnered significant press attention, China has engaged in recent months in a series of less-publicized corporate enforcement actions and initiatives against non-Chinese companies (mostly, but not exclusively, U.S.-based) operating in the country, including through new investigations, raids of China-based offices, and even detention of
New U.S. Department of Commerce Policy Further Incentivizes Disclosures of U.S. Export Control Violations
On April 18, 2023, the U.S. Department of Commerce Bureau of Industry and Security (“BIS”) released a memorandum entitled, “Clarifying Our Policy Regarding Voluntary Self-Disclosures and Disclosures Concerning Others” (the “April Memo”). The April Memo highlights additional penalties and incentives to encourage exporters – and whistleblowers – to disclose potential violations of the
FinCEN Issues Guidance on the “Who, What, When” of Beneficial Ownership Information Reporting Requirements
On March 24, 2023, the Financial Crimes Enforcement Network (“FinCEN”) issued its first set of guidance documents for its beneficial ownership reporting requirements, which take effect on January 1, 2024.
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Proposed Rule from Commerce on National Security Guardrails for CHIPS Act Funding: Restrictions on China and other Countries of Concern
The U.S. Department of Commerce (“Commerce”) is seeking public comment on how to protect national security while boosting investment in the domestic semiconductor manufacturing industry as part of a new financial incentive program established under the CHIPS and Science Act.
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