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Lise S. Test

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On June 12, 2024, the US Departments of Treasury and Commerce issued new sanctions and export controls in response to Russia’s continued war in Ukraine. Below we outline key categories of these new and expanded trade measures designed to restrict the flow of support to the Russian military-industrial base. New Sanctions Restrictions The new sanctions issued by the US Department of Treasury’s Office of Foreign Assets Control (“OFAC”) are directed at Russia’s foundational financial infrastructure…

No one size fits all When dealing with sanctions enforcement authorities in investigations, companies should have a clear understanding of an investigating agency’s expectations. These can be tricky to navigate in the current enforcement environment where multiple agencies across several jurisdictions are often actively investigating similar conduct. To compound the situation and risks, those agencies may take different approaches to communicating with a company, obtaining information or evidence from the target and third parties, and…

On May 10, 2024, the US Department of the Treasury’s Office of Foreign Assets Controls (“OFAC”) issued an interim final rule (“IFR”), effective on August 8, 2024, amending the Reporting, Procedures and Penalties Regulations under 31 CFR 510 (the “Regulations”). The IFR includes revisions and clarifications to certain procedures and reporting requirements related to certain OFAC submissions, including reports of blocked property and rejected transactions. In particular, the IFR implements the following revisions and clarifications:…

The Bureau of Industry and Security (“BIS”) issued an interim final rule (“IFR”), effective on April 19, 2024, amending the Export Administrations Regulations (“EAR”) to ease most licensing restrictions on exports/reexports to and within Australia and the UK of items subject to the EAR. This is a key change in that export licensing requirements under the EAR for Australia and the UK are now largely similar to those for Canada. The driver for this was…