On December 11, 2023, the US Departments of Commerce, the Treasury, Justice, State, and Homeland Security issued a “Quint-Seal” Compliance Note titled Know Your Cargo: Reinforcing Best Practices to Ensure the Safe and Compliant Transport of Goods in Maritime and Other Forms of Transportation (“Note”). The Note is directed at the maritime and other transportation industries—including transportation companies, maintenance companies, insurance providers, financial institutions, and “other entities involved in funding and facilitating the transport of…
On October 18, 2023, the US Departments of Commerce, State, Treasury, and Justice issued the Iran Ballistic Missile Procurement Advisory (the “Advisory”) to alert persons and businesses to Iran’s ballistic missile procurement activities. The Departments of State and Justice also issued separate statements related to the Advisory. The Advisory and related statements underscore the US Government’s concerns about Iran’s ballistic missile program and its efforts to stymie that program. In addition, the US Government and…
On September 8, 2023, the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) published a Financial Trend Analysis (“FTA”) highlighting trends related to suspected evasion of Russia-related export controls observed in reports required to be filed by financial institutions with FinCEN under the Bank Secrecy Act (“BSA”), such as through suspicious activity reports. The FTA highlights certain evasion red flags useful for purposes of companies’ own compliance efforts, while also serving as a…
On August 9, 2023, President Biden issued Executive Order 14105, targeting certain US investments into Chinese companies or Chinese-owned companies engaged in three advanced technology areas (Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern, the “EO”). The EO directs the US Department of the Treasury (“Treasury”) to issue regulations that will (1) prohibit certain categories of US outbound investments and (2) require notification of other investments involving the…