The US Treasury Department’s Office of Foreign Assets Control (“OFAC”) has issued an interim final rule to extend OFAC’s recordkeeping requirements for certain transactions from 5 to 10 years. This development mirrors the recent extension of 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”) to 10 years. Civil enforcement actions brought by OFAC for violations of IEEPA or…
On September 3, 2024, the US Department of State’s Directorate of Defense Trade Controls (“DDTC”) issued revised Guidance for U.S. Persons Abroad (“USPABs”) Authorization Requests (“USPAB Guidance”) and updated FAQs on Defense Services and USPABs. Under the International Traffic in Arms Regulations (“ITAR”), all USPABs need DDTC authorization before they can furnish ITAR-controlled defense services to any foreign person, including USPABs’ non-US employers. The principal changes to the USPAB Guidance are as follows:
Join Baker McKenzie and the Customs and International Trade Bar Association (CITBA) National Security and Sanctions Committee for a discussion of top enforcement priorities in sanctions and export controls, best practices for the private sector, and considerations for voluntary self-disclosure. The panelists for this discussion include Ian C. Richardson, Chief Counsel for Corporate Enforcement for the National Security Division of DOJ; John Sonderman, Director of the Office of Export Enforcement at BIS; and Dallas Woodrum,…
On August 23, 2024, the eve of Ukraine’s Independence Day (August 24, 2024), the US Departments of Commerce and Treasury issued new export controls and sanctions in response to Russia’s invasion of Ukraine. The new controls target the procurement networks who support Russia’s war on Ukraine and its military industrial complex and payment channels. The Commerce Department’s Bureau of Industry and Security (“BIS”) made the following changes to the Export Administration Regulations (“EAR”) and…