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”). OFAC CMP Adjustments Under OFAC’s final rule published on April 9, 2020, the adjusted penalties apply to CMPs that are assessed after April 9, 2020, as long as the violation occurred after November…
On April 10, 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued a rule amending the North Korea Sanctions Regulations (“NKSR”). The NKSR amendments implement certain provisions of the North Korea Sanctions and Policy Enhancement Act of 2016 (“NKSPEA”), as amended by the Countering America’s Adversaries Through Sanctions Act (“CAATSA”), and the National Defense Authorization Act for Fiscal Year 2020 (“2020 NDAA”). Our prior blog post on NKSPEA can be found here…
Maria Sergeyeva recently authored the blog post “Industry Groups Push Back on Commerce Department’s Proposed Supply Chain Regulations That Could Block or Restrict Tech Transactions” for Baker McKenzie’s Global Supply Chain Compliance blog. The post highlights concerns expressed by many trade associations and businesses with the highly anticipated proposed regulations issued by the US Department of Commerce to implement Executive Order 13873, “Securing the Information and Communications Technology and Services Supply Chain.” Executive Order 13873…
On April 3, 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) re-issued and extended General License No. 13E (“GL 13E”) to continue the validity period for transactions concerning Nynas AB and its subsidiaries (“Nynas”) that otherwise would be prohibited under Executive Order 13850 or Executive Order 13884 given Nynas’s 50% indirect ownership by PetrĂłleos de Venezuela S.A. (“PdVSA”). The authorization was extended through 12:01 am EST on May 14, 2020. In a…