As of May 1, the State Department has made a temporary change in the Tier I, Tier II, and new registrant payment guidelines on the Directorate of Defense Trade Controls (“DDTC”) website to reflect certain reduced registration fees to mitigate the economic impact of the COVID-19 pandemic. The DDTC is reducing fees for Tier I and Tier II registrants to $500 (reduced from $2,250 and $2,750, respectively) for registrations whose original expiration date is between…
On April 15, 2020, the US Departments of State, Homeland Security, and the Treasury (“Treasury”), and the Federal Bureau of Investigation issued an advisory warning about the cyber threat posed by North Korea, calling particular attention to banks and other financial institutions (“Advisory”). The Advisory (i) highlights North Korea’s malicious cyber activities across the globe, (ii) identifies and recommends measures to counter the cyber threat, including cybersecurity best practices, and (iii) summarizes potential enforcement actions…
On April 23, 2020, the US State Department’s Directorate of Defense Trade Controls (“DDTC”) announced certain measures intended to mitigate the impact of the COVID-19 pandemic, and key measures are summarized below: Compliance/Registration DDTC has extended the ITAR registrations expiring on February 29, March 31, April 30, May 31, and June 30, 2020 for two months from the original expiration date. Effective as of March 13, 2020, this measure implements a temporary suspension of the…
The US Treasury Department’s Office of Foreign Assets Control (“OFAC”), the US State Department (“State”), and the US Commerce Department (“Commerce”) issued rules adjusting maximum civil monetary penalties (“CMPs”) under the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015 (“FCA”). OFAC CMP Adjustments Under OFAC’s final rule published on April 9, 2020, the adjusted penalties apply to CMPs that are assessed after April 9, 2020, as long as the violation occurred after November…