The US Treasury Departmentās Office of Foreign Assets Control (āOFACā), the US Department of Stateās Directorate of Defense Trade Controls (āDDTCā), and the US Department of Commerceās Bureau of Industry and Security (āBISā) have announced increases in the maximum civil monetary penalties (āCMPsā) that may be imposed for violations of OFAC sanctions programs, the International Traffic in Arms Regulations, and the Export Administration Regulations (āEARā), respectively. The new maximum penalty amounts come into effect on August 1, 2016.
On 3 June 2016, the U.S. Commerce Departmentās Bureau of Industry and Security (āBISā) published a Final Rule (the āBIS Final Ruleā) revising a number of definitions in the Export Administration Regulations (āEARā). BIS also posted new Frequently Asked Questions related to this rule. Concurrently, the U.S. Department of State published an Interim Final Rule (the āState Interim Ruleā and, collectively with the BIS Final Rule, the āJune 2016 Rulesā) revising several definitions in the International Traffic in Arms Regulations (āITARā). 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 Departmentās Office of Foreign Assets Control (āOFACā) issued theĀ Cyber-Related Sanctions Regulations, 31 C.F.R. Part 578 (āRegulationsā), which implementĀ Executive Order 13694Ā of April 1, 2015 (āBlocking the Property of Certain Persons Engaging in Significant Malicious Cyber-Enabled Activitiesā or the āCyber EOā). Our prior blog post on the Cyber EO is availableĀ here. The Regulations implement the restrictions on transactions involving parties designated as Specially Designated Nationals (āSDNsā) under the Cyber…
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