On January 16, 2024, the United States Department of Commerce’s Bureau of Industry and Security (“BIS”) announced further enhancements to its voluntary self-disclosure (“VSD”) policy under the Export Administration Regulations (15 C.F.R Parts 730–774, the “EAR”). These enhancements build upon previous VSD developments announced on June 30, 2022 and April 18, 2023, in order to increase the efficiency and effectiveness of the VSD process. Our blog posts on these previous VSD developments are available here…
On December 22, 2023, the Biden Administration issued a new Executive Order (“EO”) “Taking Additional Steps with Respect to the Russian Federation’s Harmful Activities” (the “December 22 EO”) amending EO 14024 of April 15, 2021 (“Blocking Property With Respect To Specified Harmful Foreign Activities of the Government of the Russian Federation”) and EO 14068 of March 11, 2022 (“Prohibiting Certain Imports, Exports, and New Investment With Respect to Continued Russian Federation Aggression”). According to a…
Please check out Episode 9 of the Compliance Podcast of the Caracas office in which Jesus Davila talks to Washington DC partner, Alex Lamy, concerning the US sanctions system over the Venezuelan government and the latest decision regarding the suspension of the sanctions for the hydrocarbons and mining sectors. Alex explains the implications thereof and how this could bring new opportunities for the aforementioned sectors. A link to the podcast series is available here. Links…
Poland is an EU member state that follows a dual sanctions regime. This member state enforces EU sanctions, in addition to enforcing national sanctions that go beyond them. Businesses holding the status of an “obliged entity” under Polish AML legislation must take into account a new list of financial sanctions released on 26 September 2023. With respect to sanctions that must be complied with by all persons subject to the Polish jurisdiction, two regimes apply:…