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Alexandre (Alex) Lamy

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On April 17, 2024, the US Department of the Treasury’s Office of Foreign Assets Controls (“OFAC”) issued General License 44A (“GL 44A”), authorizing the wind down by 12:01 am EDT on May 31, 2024 of transactions that were previously authorized under GL 44. OFAC also amended a consolidated frequently asked questions (“FAQs”) guidance document (“Updated Guidance”) to reflect the reissued General License 44A. Our previous blog post on the original issuance of GL 44 can…

On March 21, 2024, the US Commerce Department’s Bureau of Industry and Security (“BIS”) published a final rule (“Final Rule”) revising and expanding the end-user controls under Part 744 of the Export Administration Regulations (“EAR”). Specifically, the Final Rule expanded end-user controls applicable to certain persons identified on the List of Specially Designated Nationals and Blocked Persons (“SDN List”) maintained by the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) under various sanctions…

The winds of change continue to swirl in the world of international sanctions enforcement. Governments around the globe are imposing new sanctions at a rapid pace and ramping up their efforts to crack down on violations. At Baker McKenzie, the Global Sanctions Investigations Group understands that navigating the ever-evolving sanctions landscape can feel like walking a tightrope. One misstep and your company could be facing material fines, reputational damage, and even criminal charges. That’s why…

On March 6, 2024, the US Department of Justice (“DOJ”), Department of Commerce’s Bureau of Industry and Security (“BIS”), and Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) jointly issued a compliance note titled “Tri-Seal Compliance Note: Obligations of foreign-based persons to comply with US sanctions and export control laws” (“Tri-Seal Compliance Note”). This note highlights longstanding US sanctions and export controls that apply to non-US companies and individuals as well as the…