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

  • Key takeaway #1 Companies should be mindful that the U.S. agencies responsible for civil and criminal export controls and sanctions compliance maintain separate VSD policies. This announcement highlights key aspects of each VSD policy.
  • 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