On March 7, 2024, the US Department of Justice (“DOJ”) National Security Division (“NSD”) published a revised Enforcement Policy for Business Organizations (“Enforcement Policy”). The Enforcement Policy was first issued by the NSD on December 13, 2019 and subsequently updated March 1, 2023. Our blog post discussing the original policy is here. In these latest updates NSD has not altered the core components of the Enforcement Policy, which provides that when a company (1) voluntary…
On January 26, 2024, the US Departments of State, Treasury, Commerce, Homeland Security, and Labor, and the Office of the US Trade Representative published a Supplemental Business Advisory (“Supplemental Advisory”) intended to highlight additional high-risk sectors and activities and update guidance for individuals, businesses, financial institutions, and other persons (e.g., investors, consultants, non-governmental organizations, due diligence service providers) regarding continued risks of doing business in Myanmar/Burma. The Supplementary Advisory incorporates significant sanctions developments against Myanmar…
On January 30, 2024, Baker McKenzie, in partnership with the International Compliance Professionals Association, hosted a virtual fireside chat with Matthew Axelrod, the Assistant Secretary for Export Enforcement for Bureau of Industry and Security (“BIS”) in the US Commerce Department. The webinar attracted 3,200 registrations from across industry, with participants raising a wide variety of questions. In the discussion with Baker McKenzie partners Janet Kim (Washington, DC) and Sunny Mann (London), Assistant Secretary Axelrod discussed…
In a new rule announced on January 23, 2024, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) has (i) expanded the scope of the Russian and Belarusian Industry Sector Sanctions under the Export Administration Regulations (“EAR”); (ii) revised restrictions aimed at preventing Iran from supplying unmanned aerial vehicles (“UAVs”) (i.e., drones) to Russia; (iii) expanding the scope of items for which there is no de minimis level of certain US-origin items incorporated…