Companies caught in the eye of the sanctions enforcement storm can only begin to effectively weather it by conducting a thorough internal investigation. These investigations are multifaceted (see our other blog posts in this series here), but an essential component is often conducting interviews. Interviews are a fundamental part of cross-border sanctions investigations that combine practical and legal challenges. Organizing them effectively requires an appreciation of practices in different jurisdictions, including local laws, customs, and…
Bipartisan legislation advancing in the U.S. Senate and the U.S. House of Representatives known as the “BIOSECURE Act” (“the Act”) has the potential to significantly restrict the ability of biotechnology companies to collaborate with certain Chinese companies without losing the ability to contract with the U.S. government. Following the same model that was used to target Chinese telecommunications companies in the late 2010s, the Act would prohibit federal “executive agencies” from contracting with or extending…
On May 28, 2024, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) amended the Cuban Assets Control Regulations (“CACR”) and issued new and updated frequently asked questions (“FAQs”) to further implement a policy originally announced by the Biden Administration on May 16, 2022 to increase support for the Cuban people and private sector entrepreneurs. The CACR has been revised as follows: OFAC has also issued six new CACR FAQs (1174–1179) and amended eight…
The US and UK introduced new prohibitions last month related to Russian-origin aluminum, copper, and nickel produced on or after April 13, 2024. The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued two determinations imposing new restrictions on the importation of Russian-origin aluminum, copper, and nickel produced on or after to April 13, 2024 (the “Covered Russian Metals”) into the United States, and on the provision by US persons or within…