On June 12, 2024, the US government announced a broad package of measures aimed at increasing the extent of economic pressure on Russia and curtailing Russian circumvention of US sanctions and export controls. The measures are a joint effort by the US Department of the Treasury’s Office of Foreign Assets Control (OFAC), the US Department
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FinCEN Proposes Expansion of CIP Requirements to Investment Advisers
On May 21, 2024, the Securities and Exchange Commission (SEC) and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) jointly published a notice of proposed rulemaking (NPRM) that would require investment advisers registered under the Investment Advisers Act of 1940 (RIAs) and exempt reporting advisers (ERAs) (collectively, “investment advisers”) to maintain customer…
DOJ’s National Security Division’s First-Ever Declination Under Its Voluntary Self-Disclosure Policy Raises Critical Questions
On May 22, 2024, the US Department of Justice’s National Security Division (“NSD”) announced its first-ever corporate declination under the NSD’s Export Control and Sanctions Enforcement Policy for Business Organizations (the “Policy”) in connection with a voluntary self-disclosure by Massachusetts biochemical company Sigma-Aldrich, Inc., doing business as MilliporeSigma. The declination related to allegations of US…
UK Issues Guidance on Oil Tanker Sales to Third Countries under the Russia Sanctions Regime
On May 21, 2024, the UK Department for Business & Trade’s Export Control Joint Unit (“ECJU”) published notice to exporters 2024/11 regarding its new guidance on the sale of oil tankers to countries other than the United Kingdom, Isle of Man, or Russia (“Third Countries”) under the Russia (Sanctions) (EU Exit) Regulations 2019 (the “Russia…
UK Imposes New Trade Sanctions on Belarus
On May 15, 2024, the Sanctions (EU Exit) (Miscellaneous Amendments and Revocations) Regulations 2024 was laid before parliament (“Regulations”). Among other things, the Regulations included a package of new trade sanctions measures under the UK’s Belarus sanctions regime targeting aluminum, as well as expanding sanctions on electronics (including semiconductors, electronic integrated circuits, and the machinery…
A Round-Up of Recent Changes to OFSI Financial Sanctions Guidance
This month has seen HM Treasury’s Office of Financial Sanctions Implementation (“OFSI”) roll out a new FAQ guidance format, as well as update a number of its existing guidance documents. In particular, OFSI has introduced changes to its enforcement and civil monetary penalties guidance, as well as to its general financial sanctions guidance in relation…
OFAC Amends Reporting Requirements – Important Considerations for Compliance
On May 10, 2024, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued an Interim Final Rule, effective August 8, 2024 (the “IFR”), that clarifies the scope of OFAC’s rejected transaction reporting requirement, and introduces other amendments to the Reporting, Procedures and Penalties Regulations (“RPPR”) at 31 CFR Part 501.…
BIS Removes Significant Export Control License Requirements for Australia and the UK under the Strategic AUKUS Partnership
On May 8, 2024, BIS published a correction to the interim final rule, further removing license requirements for certain items under ECCN 0x5zz.
Previously, the interim final rule stated that all 0x5zz ECCNs referenced in footnote 9 to the Commerce Country Chart in supplement no. 1 to part 738 that were previously controlled for NS1…
Trilateral AUKUS Partnership Further Strengthened with Proposed New U.S. ITAR Exemptions and UK Open General Licenses
May 1, 2024, saw two major developments under the Australia, United Kingdom, and United States (“AUKUS”) Trilateral Security Partnership.
First, the U.S. Department of State (the “Department”) issued a notice of proposed rulemaking (“NPRM”) that would amend the International Traffic in Arms Regulations (“ITAR”) to create an exemption for certain exports, reexports, retransfers, or temporary imports…
President Signs Expansive Sanctions Bill Into Law; Doubling of Limitations Period for IEEPA Violations Likely to Have Major Impact
On April 24, 2024, President Biden signed HR 815, “Making emergency supplemental appropriations for the fiscal year ending September 30, 2024, and for other purposes,” into law (the “National Security Supplemental” or the “NSS”). The National Security Supplemental appropriates funds to provide security assistance to Ukraine, Israel, and US partners in the Indo-Pacific and…