On December 22, 2023, President Biden signed into law the National Defense Authorization Act (“NDAA”) for Fiscal Year 2024 (P.L. 118-31). A must-pass piece of legislation that funds Department of Defense (“DoD”) operations on an annual basis, the NDAA is a frequent vehicle for trade-related provisions and legislative changes affecting DoD acquisition policies with direct implications for government contractors. The measure includes a number of provisions relating to US export controls, sanctions, and supply chain…
On December 5, 2023 and December 6, 2023, respectively, the US and UK Governments announced new sanctions and export control measures targeting Russia focused on persons and entities in third countries supporting Russia’s military and defense industrial base and its war in Ukraine. US Sanctions and Export Control Updates The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced sanctions targeting a network led by Belgium-based individual, Hans De Geetere, as well…
On November 6, 2023, the Department of Commerce’s Bureau of Industry Security (“BIS”) and the Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) published a joint notice (“Joint Notice”) to announce a new Suspicious Activity Report (“SAR”) key term for financial institutions when reporting possible attempts by entities or individuals to evade US export controls. This builds on similar efforts by BIS and FinCEN to require SARs for transactions related to transactions that may…
On October 31, 2023, the US, UK, and Canadian governments imposed further coordinated sanctions against Myanmar (Burma) through designations of individuals and entities associated with Myanmar’s military regime and a US prohibition on the provision of financial services to Myanma Oil and Gas Enterprise (“MOGE”). The measures aim to prevent the Burmese military from obtaining access to arms and other supplies and are part of an effort to unify sanctions measures on Myanmar across the…