The US Treasury Department’s Office of Foreign Assets Control (“OFAC”), the US Department of State’s Directorate of Defense Trade Controls (“DDTC”), and the US Department of Commerce’s Bureau of Industry and Security (“BIS”) have announced increases in the maximum civil monetary penalties (“CMPs”) that may be imposed for violations of OFAC sanctions programs, the International Traffic in Arms Regulations, and the Export Administration Regulations (“EAR”), respectively. The new maximum penalty amounts come into effect on August 1, 2016.
On 3 June 2016, the U.S. Commerce Department’s Bureau of Industry and Security (“BIS”) published a Final Rule (the “BIS Final Rule”) revising a number of definitions in the Export Administration Regulations (“EAR”). BIS also posted new Frequently Asked Questions related to this rule. Concurrently, the U.S. Department of State published an Interim Final Rule (the “State Interim Rule” and, collectively with the BIS Final Rule, the “June 2016 Rules”) revising several definitions in the International Traffic in Arms Regulations (“ITAR”). The June 2016 Rules will go into effect on 1 September 2016. The State Department will accept comments on the State Interim Rule until 5 July 2016.
On Thursday, December 31, 2015, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued the Cyber-Related Sanctions Regulations, 31 C.F.R. Part 578 (“Regulations”), which implement Executive Order 13694 of April 1, 2015 (“Blocking the Property of Certain Persons Engaging in Significant Malicious Cyber-Enabled Activities” or the “Cyber EO”). Our prior blog post on the Cyber EO is available here. The Regulations implement the restrictions on transactions involving parties designated as Specially Designated Nationals (“SDNs”) under the Cyber…
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