After the United Kingdom imposed new restrictions on legal advisory services on 30 June 2023, it is becoming increasingly more complicated for organizations to gauge what kinds of legal advice they are able to provide with respect to Russia. As these restrictions apply to in house legal and compliance functions as well as law firms
The U.S. Department of Justice (DOJ), Bureau of Industry and Security (BIS), and Office of Foreign Assets Control (OFAC) published their second Tri-Seal Compliance Note on July 26 summarizing their voluntary self-disclosure procedures for export control and sanctions violations. The Note highlights the potential benefits of self-disclosure, including significant mitigation of civil and criminal liability.
Although 2021 has predominantly been referred to as the “year of Russia” in terms of sanctions, the collapse of nuclear talks (JCPOA) as well as the social repression in the country have also shifted the focus to Iran, to some degree.
While designating members of the Islamic Revolutionary Guards Forces (IRGF) as Specially Designated Nationals
In coordination with the G7 and other international partners, the U.S. implemented new Russia-related sanctions and export controls on May 19, 2023. The U.S. also released an additional select list of potential export control evasion “red flags.”
Restrictive economic measures
The Office of Foreign Assets Control (OFAC):
The Civil Rights Division of the Department of Justice has issued guidance clarifying that when a position requires access to export-controlled information or items, that requirement is not a basis for making an employment decision based on citizenship, immigration status, or national origin.
In our recent alert on reedsmith.com, we examine U.S. export control
The Bureau of Industry and Security (BIS) has clarified two enforcement policies in an attempt to incentivize voluntary self-disclosures and disclosures about others’ possible violations of the Export Administration Regulations (EAR).
In our recent post, we consider the implications of this latest development.
An alert was issued by the U.S. Office of Foreign Assets Control (OFAC) on April 17 warning about the potential evasion of the Russian-origin oil price cap. The alert came after OFAC had received reports that oil exported from the Eastern Siberia Pacific (ESPO) pipeline or ports on Russia’s eastern coast was trading above the
The U.S Department of Commerce recently released the first of three expected Notices of Funding Opportunities under the CHIPS and Science Act of 2022. This act aims to develop the domestic semiconductor supply chain, provide jobs, restore the country’s leadership in semiconductor manufacturing, and advance U.S. national and economic security.
In our latest alert, found on reedsmith.com
A Tri-Seal Compliance Note (“Note”) has been released by the Department of Commerce, Department of Treasury, and Department of Justice to assist businesses in identifying warning signs and implementing appropriate compliance measures to ensure cooperation with Russian-related sanctions and export controls. One of the most common sanction evasion tactics highlighted in the Note is the
Amid heightened tensions between the U.S. and China, the Ministry of Commerce of the People’s Republic of China recently announced measures to add Lockheed Martin Corporation and Raytheon Missiles & Defense to its Unreliable Entity List, which, amongst other things, bars both U.S. companies from import and export trade with China and any new investment