In two separate rounds of sanctions designations in the past week, the United States added more parties to the Specially Designated Nationals List (“SDN List”) maintained by the Office of Foreign Assets Control (“OFAC”) in the US Treasury Department. These designations are noteworthy given their scope and, in the case of the Iran-related designations, the fact that they included parties in China, Russia, and Türkiye. Not only does this increase the risk of encountering sanctioned…
On July 19, 2023, the Bureau of Industry and Security (“BIS”) in the US Commerce Department published much-anticipated guidance for license applications involving medical-related items destined to Russia, Belarus, and the Occupied/Covered Regions of Ukraine (Crimea, Donetsk People’s Republic, and Luhansk People’s Republic). The guidance is just over three pages long, and we recommend that companies submitting applications for medical-related items to these destinations review the document in full. While BIS has been communicating many…
On 28 June 2023, the US Bureau of Industry and Security (“BIS”) announced that the “Five Eyes” countries (Australia, Canada, New Zealand, the United Kingdom and the United States) have agreed to formally coordinate on export control enforcement, with a particular emphasis on the export controls targeting Russia and Belarus, which have been a core tool in the broader sanctions toolbox. Baker McKenzie has deep export controls expertise in four of the Five Eyes countries: …
How can companies prepare in an era of increased sanctions enforcement and investigations? In this video, partners Kerry Contini and Alex Lamy share their advice to companies navigating the rapidly evolving sanctions landscape. As rules become more restrictive, companies should brace themselves for increased compliance risks and routinely review their compliance programs. It is also critical to prepare for cross-border investigations that require a technical understanding of the nuanced rules and their interplay across multiple…