Please join Baker McKenzie and ICPA for a fireside chat with Lawrence Scheinert, Associate Director for Enforcement, Compliance, and Analysis at the US Treasury Department’s Office of Foreign Assets Control (OFAC). During the discussion, Lawrence will outline OFAC’s enforcement program and priorities. He will also share his insights on enforcement actions, multilateral coordination and cooperation with other US regulators such as BIS, FinCEN, and the DOJ, impact of enforcement actions on non-US companies, among other topics. Please…
On April 17, 2024, the US Department of the Treasury’s Office of Foreign Assets Controls (“OFAC”) issued General License 44A (“GL 44A”), authorizing the wind down by 12:01 am EDT on May 31, 2024 of transactions that were previously authorized under GL 44. OFAC also amended a consolidated frequently asked questions (“FAQs”) guidance document (“Updated Guidance”) to reflect the reissued General License 44A. Our previous blog post on the original issuance of GL 44 can…
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 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…