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Rob O'Brien

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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,…

On March 7, 2024, the US Department of Justice (“DOJ”) National Security Division (“NSD”) published a revised Enforcement Policy for Business Organizations (“Enforcement Policy”). The Enforcement Policy was first issued by the NSD on December 13, 2019 and subsequently updated March 1, 2023. Our blog post discussing the original policy is here. In these latest updates NSD has not altered the core components of the Enforcement Policy, which provides that when a company (1) voluntary…

On January 30, 2024, Baker McKenzie, in partnership with the International Compliance Professionals Association, hosted a virtual fireside chat with Matthew Axelrod, the Assistant Secretary for Export Enforcement for Bureau of Industry and Security (“BIS”) in the US Commerce Department. The webinar attracted 3,200 registrations from across industry, with participants raising a wide variety of questions. In the discussion with Baker McKenzie partners Janet Kim (Washington, DC) and Sunny Mann (London), Assistant Secretary Axelrod discussed…