The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), the US Department of State (“State”), the US Department of Commerce (“Commerce”), and the US Department of Energy (“DOE”) issued rules adjusting maximum civil monetary penalties (“CMPs”) under the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015, as outlined below. (For additional years of CMPs, see our previous blog post available here.) OFAC CMP Adjustments Under OFAC’s final rule issued on January 15, 2025,…
On October 30, 2024, the US Government imposed sanctions on hundreds of entities and individuals across the globe, primarily in response to Russia’s continued war in Ukraine, and amended US export controls related to Russia and Belarus. Below, we describe the key actions taken by the US Departments of the Treasury, State, and Commerce. 1. OFAC Actions With the aim of disrupting global sanctions evasion networks and domestic suppliers to Russia’s military-industrial base, the US…
On October 9, 2024, the US Commerce Department’s Bureau of Industry and Security (“BIS”) issued guidance to financial institutions on best practices for compliance with the US Export Administrations Regulations (“EAR”). The guidance aims to help financial institutions minimize the inadvertent EAR violations, especially under General Prohibition 10 (“GP 10”), which prohibits financing or servicing items subject to the EAR with knowledge that a violation of the EAR has occurred, is about to occur, or…
The main US export controls regulator continues to take steps to demonstrate its focus on enforcement. Specifically, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule (the “Rule”) on September 16, 2024, effective immediately, to amend the provisions in its regulations focused on the voluntary self-disclosure (“VSD”) process. Many of the changes in the Rule reflect guidance previously issued by BIS in individual memoranda (available here), which are now…