On July 22, 2024, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued guidance relating to OFAC’s implementation of the 21st Century Peace Through Strength Act (“Act”), included in H.R. 815 and signed into law on April 24, 2024, which extended the statute of limitations for civil and criminal violations of the International Emergency Economic Powers Act (“IEEPA”) and the Trading with the Enemy Act (“TWEA”) from five to 10 years. Together, the…
On May 16, 2024, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published a final rule amending the Iranian Transactions and Sanctions Regulations, 31 C.F.R Part 560 (“ITSR”), to incorporate OFAC General License (“GL”) D-2 and the preexisting list of items deemed incident to communications that are authorized for export or reexport to Iran under GL D-2, and to concurrently update such list. OFAC also published one new and 26 revised…
On April 18, 2024, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) and the UK’s Foreign, Commonwealth & Development Office (“FCDO”) announced a coordinated sanctions package targeting Iran. In the US, OFAC added 16 individuals and 10 entities to the Specially Designated Nationals and Blocked Persons List (“SDN List”) and the US Commerce Department’s Bureau of Industry and Security (“BIS”) also expanded the scope of Foreign Direct Product (“FDP”) rules for foreign-produced items…
In an era where regulatory compliance is under intense scrutiny, the importance of a well-orchestrated response to trade and sanctions investigations cannot be overstated. An investigation may involve transactions occurring in multiple jurisdictions, laws of separate jurisdictions, and inquiries from (or disclosures to) multiple governmental authorities. Investigations may begin through an internal whistleblower or other internal discovery, which grants the company more discretion in directing the tempo and scope of the investigation. In other instances,…