On March 6, 2024, the US Department of Justice (“DOJ”), Department of Commerce’s Bureau of Industry and Security (“BIS”), and Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) jointly issued a compliance note titled “Tri-Seal Compliance Note: Obligations of foreign-based persons to comply with US sanctions and export control laws” (“Tri-Seal Compliance Note”). This note highlights longstanding US sanctions and export controls that apply to non-US companies and individuals as well as the…
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 26, 2024, the US Departments of State, Treasury, Commerce, Homeland Security, and Labor, and the Office of the US Trade Representative published a Supplemental Business Advisory (“Supplemental Advisory”) intended to highlight additional high-risk sectors and activities and update guidance for individuals, businesses, financial institutions, and other persons (e.g., investors, consultants, non-governmental organizations, due diligence service providers) regarding continued risks of doing business in Myanmar/Burma. The Supplementary Advisory incorporates significant sanctions developments against Myanmar…
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…