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Vivian Tse

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As regulations evolve and enforcement intensifies, effective documentation of sanctions investigation results has never been more critical. Proper documentation is crucial not only for maintaining legal privileges and the confidentiality of sensitive information, but also for supporting legal defenses in potential regulatory enforcement in the future. Additionally, companies may have an obligation to disclose investigation results to their external auditors, shareholders, and other stakeholders (e.g., transaction counterparties), underscoring the importance of appropriate documentation to ensure…

On May 10, 2024, the US Department of the Treasury’s Office of Foreign Assets Controls (“OFAC”) issued an interim final rule (“IFR”), effective on August 8, 2024, amending the Reporting, Procedures and Penalties Regulations under 31 CFR 510 (the “Regulations”). The IFR includes revisions and clarifications to certain procedures and reporting requirements related to certain OFAC submissions, including reports of blocked property and rejected transactions. In particular, the IFR implements the following revisions and clarifications:…

On March 21, 2024, the US Commerce Department’s Bureau of Industry and Security (“BIS”) published a final rule (“Final Rule”) revising and expanding the end-user controls under Part 744 of the Export Administration Regulations (“EAR”). Specifically, the Final Rule expanded end-user controls applicable to certain persons identified on the List of Specially Designated Nationals and Blocked Persons (“SDN List”) maintained by the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) under various sanctions…

On February 1, 2024, President Biden issued Executive Order 14115 (“EO 14115”) targeting persons involved in activities that threaten the peace, security, and stability in the West Bank. Meanwhile, the UK government announced on 12 February 2024 sanctions on “extremist Israeli settlers” who have committed human rights abuses against Palestinian communities. Pursuant to EO 14115, four individuals were added to the Specially Designated Nationals and Blocked Persons List (“SDN List”). Concurrently, the US Treasury Department’s…