On July 23, 2024, the Office of Foreign Assets Control (“OFAC”) in the US Treasury Department announced that it was publishing a notice requiring financial institutions holding Russian sovereign assets to report those assets to OFAC no later than August 2, 2024 or within 10 days of the detection of such assets. This new reporting requirement implements the “Rebuilding Economic Prosperity and Opportunity for Ukrainians Act” or the “REPO for Ukrainians Act”, which US President…
On July 10, 2024, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued guidance on addressing the risks of diversion of items subject to US export controls to countries or parties of concern (the “Guidance”). The Guidance summarizes mechanisms that BIS uses to notify companies and universities about parties that present diversion risks and that do not appear on its screening lists, as well the level of due diligence BIS expects in…
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…
For the second week of our Annual Compliance Conference, we discussed key trade compliance issues impacting our clients globally. Specifically, we discussed the trade policy response of the US, EU and U.K. to ever increasing geopolitical disruption, global strategies for handling sanctions regulators and enforcement, and key global sanctions and export controls developments. Trade policy response to geopolitical disruption – China and beyond Tuesday 7 May SPEAKERS: Tristan Grimmer (Partner, London), Sylwia Lis (Partner, Washington…