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 13,…
On December 16, 2022, the US Department of State’s Directorate of Defense Trade Controls (“DDTC”) issued a proposed rule that would treat two additional types of transactions as activities that are not exports, reexports, retransfers, or temporary imports (“controlled events”) (and, thus, not require authorization) under the International Traffic in Arms Regulations (“ITAR”). The two additional activities that would not constitute controlled events are: Taking defense articles outside a previously approved country by the armed…
On December 5, 2022, the US Department of State’s Directorate of Defense Trade Controls (“DDTC”) issued the International Traffic in Arms Regulations (“ITAR”) Compliance Program Guidelines (“ITAR Guidelines”). The ITAR Guidelines set out DDTC’s expectations for an effective ITAR Compliance Program (“ICP”) and an introduction to controls contained in the Arms Export Control Act and ITAR. More specifically, the ITAR Guidelines outline key elements of an effective ICP, and identify suggestions, common compliance pitfalls, and/or…
On November 22, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published a new determination pursuant to Executive Order 14071 of April 6, 2022 (“EO 14071”) – “Determination Pursuant to Section 1 (a)(ii) of EO 14071” (“Determination”). The Determination implements the price cap policy for Russian crude oil, as anticipated based on OFAC’s September 2022 preliminary guidance related to the implementation of the policy banning the provision of services related to…