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Lise S. Test

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On August 23, 2024, the eve of Ukraine’s Independence Day (August 24, 2024), the US Departments of Commerce and Treasury issued new export controls and sanctions in response to Russia’s invasion of Ukraine. The new controls target the procurement networks who support Russia’s war on Ukraine and its military industrial complex and payment channels. The Commerce Department’s Bureau of Industry and Security (“BIS”) made the following changes to the Export Administration Regulations (“EAR”) and…

The US Commerce Department’s Bureau of Industry and Security (“BIS”) has issued a final rule (“Final Rule”), effective July 23, 2024, expanding the jurisdictional scope of the Export Administration Regulations’ (“EAR”) Iran Foreign Direct Product Rule (“Iran FDP Rule”) over more foreign-made items and imposing a licensing requirement for the in-country transfer within Iran of items subject to the EAR under the Iran FDP Rule. This expansion of controls was made to implement the requirements…

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. 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 and access to…

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…