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…
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 February 16, 2024, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a Compliance Communiqué containing Guidance for the Provision of Humanitarian-Related Assistance and Critical Commodities to the Yemeni People (“Guidance”). The Guidance follows the January 17, 2024 announcement of the redesignation of Ansarallah (or Ansar Allah), commonly known as the Houthis, as a Specially Designated Global Terrorist (“SDGT”) , which became effective on February 16, 2024. The same day,…