On August 15, 2024, the US Department of State’s Directorate of Defense Trade Controls (“DDTC”) published the long-awaited final rule (“Final Rule”), effective September 16, 2024, expanding the definition of “activities that are not exports, reexports, retransfers, or temporary imports” pursuant to Section 120.54 of the International Traffic in Arms Regulations (“ITAR”). Please see our previous blog here when DDTC issued a proposed rule (“Proposed Rule”) to make these changes. The Final Rule adds…
On July 22, 2024, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued guidance relating to OFAC’s implementation of the 21st Century Peace Through Strength Act (“Act”), included in H.R. 815 and signed into law on April 24, 2024, which extended the statute of limitations for civil and criminal violations of the International Emergency Economic Powers Act (“IEEPA”) and the Trading with the Enemy Act (“TWEA”) from five to 10 years. Together, the…
On July 23, 2024, the Office of Foreign Assets Control (“OFAC”) in the US Treasury Department announced that it was publishing a notice requiring financial institutions holding Russian sovereign assets to report those assets to OFAC no later than August 2, 2024 or within 10 days of the detection of such assets. This new reporting requirement implements the “Rebuilding Economic Prosperity and Opportunity for Ukrainians Act” or the “REPO for Ukrainians Act”, which US President…
On June 18, 2024, Baker McKenzie, in partnership with the International Compliance Professionals Association, hosted a virtual fireside chat with Lawrence Scheinert, the Associate Director for Compliance and Enforcement at the Office of Foreign Assets Control (“OFAC”) in the US Treasury Department. The webinar attracted 1640 registrations from across industry, with participants raising a wide variety of questions. In the discussion with Baker McKenzie partners, led by Julia Webster (Toronto) with questions from Janet Kim…