The US Treasury Department’s Office of Foreign Assets Control (“OFAC”), the US State Department (“State”), and the US Commerce Department (“Commerce”) issued rules adjusting maximum civil monetary penalties (“CMPs”) under the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015 (“FCA”), as outlined below. (For additional years of CMPs, see our previous blog post available here.) OFAC CMP Adjustments Under OFAC’s final rule published on March 17, 2021, the adjusted penalties apply to CMPs…
On April 9, 2021, the US Commerce Department’s Bureau of Industry and Security (“BIS”) strengthened restrictions targeting Burma by adding Burma to the list of countries subject to the Export Administration Regulations’ (“EAR’s”) military-intelligence end-use and end-user controls and controls on certain support activities by US persons (“Interim Final Rule”). These controls were first issued on January 15, 2021 (“January Rule”), and became effective March 16, 2021. Our blog posts on other recent sanctions targeting…
On March 29, 2021, the Commerce Department published an advance notice of proposed rulemaking (“ANPRM”) seeking public comment on potential licensing or other pre-clearance processes for transactions under the regulations that took effect on March 22, 2021 to implement Executive Order 13873, “Securing the Information and Communications Technology and Services Supply Chain” (“Executive Order 13873”). Executive Order 13873 authorizes the Commerce Department to block or impose conditions on transactions involving information and communications technology and…
On March 18, 2021, the US State Department (“State”) published in a Federal Register notice that formally outlines the various US export controls targeting Russia that will be strengthened pursuant to the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (“CBW Act”) as a result of State’s determination that the Russian Government had used a chemical weapon against its own nationals in violation of international law. These measures were previously announced by…