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…
On May 1, 2024, the US Department of the Treasury’s Office of Foreign Assets Controls (“OFAC”) and the US Department of State designated nearly 300 individuals, entities, and vessels to the List of Specially Designated Nationals and Blocked Persons (“SDN List”) mainly targeting Russia’s military capacity. On the same day, OFAC also issued three new general licenses (“GLs”) authorizing limited transactions involving certain SDNs. We summarize these developments below. SDN Designations According to OFAC’s press…