Author

Andrea Tovar

Browsing

On April 15, 2020, the US Departments of State, Homeland Security, and the Treasury (“Treasury”), and the Federal Bureau of Investigation issued an advisory warning about the cyber threat posed by North Korea, calling particular attention to banks and other financial institutions (“Advisory”). The Advisory (i) highlights North Korea’s malicious cyber activities across the globe, (ii) identifies and recommends measures to counter the cyber threat, including cybersecurity best practices, and (iii) summarizes potential enforcement actions…

On April 27, 2020, US Customs and Border Protection (“CBP”) published a set of Frequently Asked Questions available here (“FAQ Guidance”) regarding the export of personal protective equipment products (“PPE Products”) covered under the temporary final rule published by the Federal Emergency Management Agency (“FEMA Rule”). Our blog posts on the FEMA Rule, related exemptions, and other developments are available here. The FAQ Guidance provided via a bulletin in CBP’s Cargo Systems Messaging Service includes important information regarding the…

On February 18, 2019, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), pursuant to Executive Order 13850 (“EO 13850”), designated Rosneft Trading S.A., the Swiss-incorporated, Russian-controlled oil brokerage firm, as a Specially Designated National (“SDN”) for operating in the oil sector of the Venezuelan economy. OFAC also designated the President and Chairman of Rosneft Trading S.A., Didier Casimiro, as an SDN for purporting to act for or on behalf of, directly…

On December 13, 2019, the US Department of Justice’s (“DOJ”) National Security Division (“NSD”) released a revised policy regarding voluntary self-disclosures of willful export control and sanctions violations (the “Policy”).  The Policy reiterates DOJ’s commitment to pursue willful violations of export control and sanctions violations, and supersedes the DOJ’s “Guidance Regarding Voluntary Self-Disclosures, Cooperation, and Remediation in Export Control and Sanctions Investigations Involving Business Organizations,” dated October 2, 2016 (“2016 Guidance”).

The Policy clarifies the requirements for companies seeking to receive credit for voluntary self-disclosures (“VSD”) of willful export control or sanctions violations, and sets forth the potential benefit to companies who meet the requirements set forth in the Policy.