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

Feb. 23, 2024–Today, following the death of opposition politician and anti-corruption activist Aleksey Navalny, and after two years of Russia’s unprovoked and unlawful full-scale invasion of Ukraine, the Commerce Department’s Bureau of Industry and Security (BIS) imposed additional export restrictions on 93 entities under 95 entries in Russia and seven other destinations. Sixty-three of the

Earlier this week, the U.S. government partially re-implemented certain recently relaxed sanctions against Venezuela. According to a statement released by the United States Department of State on January 30th, the absence of meaningful progress in allowing candidates of the opposition Unitary Platform to stand for office in the upcoming Venezuelan presidential election has

What You Need to Know

  • Key takeaway #2 Failure to initiate an internal investigation promptly after discovering a potential export controls or sanctions
  • Last Friday, the U.S. Departments of Commerce, Justice, State, and the Treasury issued a joint guidance sheet on Iran’s unmanned aerial vehicles (“UAVs”) program (the “Iran UAV Guidance”). The Iran UAV Guidance highlighted (I) the threat Iran’s UAV program poses; (II) the key items that Iran relies on to expand its UAV program; (III) the