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Michael Amberg

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In a new rule announced on January 23, 2024, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) has (i) expanded the scope of the Russian and Belarusian Industry Sector Sanctions under the Export Administration Regulations (“EAR”); (ii) revised restrictions aimed at preventing Iran from supplying unmanned aerial vehicles (“UAVs”) (i.e., drones) to Russia; (iii) expanding the scope of items for which there is no de minimis level of certain US-origin items incorporated…

On December 11, 2023, the US Departments of Commerce, the Treasury, Justice, State, and Homeland Security issued a “Quint-Seal” Compliance Note titled Know Your Cargo: Reinforcing Best Practices to Ensure the Safe and Compliant Transport of Goods in Maritime and Other Forms of Transportation (“Note”). The Note is directed at the maritime and other transportation industries—including transportation companies, maintenance companies, insurance providers, financial institutions, and “other entities involved in funding and facilitating the transport of…

On October 31, 2023, the US, UK, and Canadian governments imposed further coordinated sanctions against Myanmar (Burma) through designations of individuals and entities associated with Myanmar’s military regime and a US prohibition on the provision of financial services to Myanma Oil and Gas Enterprise (“MOGE”). The measures aim to prevent the Burmese military from obtaining access to arms and other supplies and are part of an effort to unify sanctions measures on Myanmar across the…

On September 8, 2023, the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) published a Financial Trend Analysis (“FTA”) highlighting trends related to suspected evasion of Russia-related export controls observed in reports required to be filed by financial institutions with FinCEN under the Bank Secrecy Act (“BSA”), such as through suspicious activity reports. The FTA highlights certain evasion red flags useful for purposes of companies’ own compliance efforts, while also serving as a…