In the midst of ongoing sanctions investigations and enforcement actions, companies are faced with yet another challenge: interested third-party stakeholders. Companies must decide who to share information with, what levels and types of information to share, how to share information, and how to mitigate the risks of loss of legal privilege, leaks, and triggering disclosure/reporting obligations by others. In this blog post, the Global Sanctions Investigations Group focuses on three critical third party stakeholders –…
The US Commerce Department’s Bureau of Industry and Security (“BIS”) has issued amendments to the Export Administration Regulations, 15 C.F.R. Parts 730-774 (“EAR”) that, most significantly, define the scope of “standards-related activities” that are subject to US export controls jurisdiction under the EAR. The purpose of these amendments is to ensure that US export controls and associated compliance concerns do not impede the participation and leadership of US companies in legitimate standards-related activities. BIS also…
On May 16, 2024, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published a final rule amending the Iranian Transactions and Sanctions Regulations, 31 C.F.R Part 560 (“ITSR”), to incorporate OFAC General License (“GL”) D-2 and the preexisting list of items deemed incident to communications that are authorized for export or reexport to Iran under GL D-2, and to concurrently update such list. OFAC also published one new and 26 revised…
On March 29, 2024, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) released an interim final rule, effective April 4, 2024 (“April 2024 IFR”) to correct inadvertent errors made in prior semiconductor-related rules in the Export Administration Regulations (“EAR”) and further clarify such rules. The April 2024 IFR clarifies the (1) “Implementation of Additional Export Controls: Certain Advanced Computing Items; Supercomputer and Semiconductor End Use; Updates and Corrections” (88 FR 73458, October…