Archives: Export Controls & Sanctions

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Training Opportunity: Discussion on Tech-centric Anticorruption and Sanctions Compliance – 20 September, London

20 September 2019  9:30 a.m. – 2:30 p.m. BST Register through techUK (favorable registration rate available to members) Register through eventbrite (event open to non-techUK members) Joining forces with techUK, Content Enablers and Dun & Bradstreet, our International Trade Practice is hosting a timely discussion on tailored approaches for UK technology businesses to effectively navigate … Continue Reading

Recent Cuba Travel-related Settlements With OFAC Demonstrate Importance of Robust Sanctions Compliance Program

On June 13, 2019, the US Treasury Department’s Office of Foreign Assets Control (OFAC) announced settlements with three travel companies – Expedia Group, Inc. (Expedia), Hotelbeds USA, Inc. (Hotelbeds USA) and Cubasphere Inc. (Cubasphere) – for their alleged involvement in booking travel to Cuba or arranging trips for Cuban nationals between 2011 and 2014.… Continue Reading

US Adds Five Chinese Companies to the Department of Commerce Entity List

On June 24, 2019, the US Department of Commerce, Bureau of Industry and Security (BIS) published in the Federal Register a Final Rule designating five entities, all located in China, to the Entity List. The five entities are: Chengdu Haiguang Integrated Circuit – aliases include Hygon and Chengdu Haiguang Jincheng Dianlu Sheji Chengdu Haiguang Microelectronics Technology – aliases include HMC … Continue Reading

Training Material Available: Export Controls and Technology Transfers Conference – June 19-20, 2019 | Washington DC

George Grammas’s presentation on “Strengthening Trade Compliance in Line with Recent Legislative Developments and Impacts to Controls via an Examination of Extraterritorial Applications, Order of Review, and Classification” is now available in our Learning Center, in which you can also find other training resources and information.… Continue Reading

Huawei Motions for Summary Judgement in Complaint Against US Government

On May 28, 2019, Huawei Technologies Co., Ltd., a Chinese telecommunications company, and its US-based affiliate, Huawei Technologies USA, Inc. (collectively “Huawei”), filed a Motion for Summary Judgment. (See Plaintiffs’ Motion for Summary Judgment, Huawei Technologies USA, Inc. et al v. United States of America, et al, No. 4-19-cv-159-ALM (E.D. Tex. filed May 28, 2019) … Continue Reading

US-Russia: Anticorruption, Sanctions, Counter-sanctions and Compliance for Companies Doing Business – Webinar Presentation Material – Russian Counter-sanction Legislation

Russian Counter-sanctions: Bill Introduced to Criminalize Dissemination of Information That May Result in Introduction or Expansion of Sanctions Against Russian Persons Following our recent webinar, our Moscow Team prepared an analysis of a draft Russian legislation that would prohibit media communications that reveal non-compliance with sanctions or facilitate imposition of sanctions and would also impose criminal … Continue Reading

US Commerce Department Offers Huawei and Affiliated Suppliers Interim Reprieve by Granting Temporary General License Until August 2019

On May 22, 2019, the US Department of Commerce, Bureau of Industry and Security (BIS) is expected to publish in the Federal Register a Final Rule creating a 90-day Temporary General License (TGL) for Huawei Technologies Co., Ltd. (Huawei) and the 68 affiliated Huawei entities (collectively, the “Huawei Listed Companies”) that were added to the … Continue Reading

US Changes Policy on Helms-Burton Act – Litigation Strategy for Companies Active in Cuba

On May 2, the Trump Administration ceased waiving Title III of the Helms-Burton Act, thus allowing US individuals and companies to file lawsuits against companies that are operating in Cuba and “trafficking” in (meaning, using or profiting from) property in Cuba which was confiscated from them by the government of Cuba. (For additional details, read our earlier publication.) The … Continue Reading

Trump Secures US Telecom Supply Chain with Executive Order; Related Huawei Actions

On May 15, 2019, President Donald Trump issued an Executive Order (EO) titled “Securing the Information and Communications Technology and Services Supply Chain.” The long-awaited EO addresses the use in US communications networks of technologies from certain types of foreign companies.… Continue Reading

US Adds Huawei and Affiliates to the Department of Commerce Entity List – What to Expect From the Final Rule

On May 21, 2019 the US Commerce Department, Bureau of Industry and Security (BIS) is expected to publish in the Federal Register a Final Rule designating Huawei Technologies Co., Ltd. (Huawei) and 68 affiliated Huawei entities located in 26 countries (collectively, the “Huawei Listed Companies”) to the Entity List. … Continue Reading

The Real Significance of OFAC’s Sanctions Compliance Guidance | Sanctions Webinar on May 16, 2019

On May 2, 2019, the US Department of Treasury’s Office of Foreign Assets Control (OFAC) released guidance on effective sanctions compliance programs. While this is the first document of this kind from OFAC, similar guidance documents by the US Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) have been on the books … Continue Reading

Deadline Approaches for Certain Transitioning USML Category Items to CCL

Due to the Export Control Reform (ECR) that began nearly six years ago, the Department of States’s Directorate of Defense Trade Controls (DDTC) has updated 18 of the 21 categories in the United States Munitions List (USML), and most of these categories had items transition to the Commerce Control List (CCL) of the Export Administration Regulations (EAR) by respective … Continue Reading

DDTC Fines Alleged Violations of ITAR and Failure to Appoint Qualified Empowered Offcial

On February 28, 2019, with a civil penalty of US$400,000, Darling Industries, Inc. of Tucson, Arizona settled allegations for violating six counts of the Arms Export Control Act (AECA), as well as the International Traffic in Arms Regulations (ITAR), in connection with unauthorized exports of defense articles, provisions of defense services and failure to appoint a qualified Empowered Official.… Continue Reading

OFAC Reaches Settlement Agreement With e.l.f. Cosmetics, Inc.

On January 31, 2019, the Department of Treasury’s Office of Foreign Assets Control (OFAC) announced that it has reached a settlement agreement with e.l.f. Cosmetics, Inc. in the amount of US$996,080 for potential civil liability relating to 156 apparent violations of North Korea Sanctions Regulations. The potential violations stem from importation of false eyelash kits from the People’s Republic of … Continue Reading

OFAC Issues New Venezuela-related Executive Order and General Licenses

On January 28, 2019, the Department of Treasury’s Office of Foreign Assets Control (OFAC) announced that it has designated Petroleos de Venezuela, S.A. (PdVSA) following Executive Order (E.O.) 13850, after a determination by Treasury Secretary Steven T. Mnuchin and Secretary of State Michael Pompeo that PdVSA was operating in the Venezuelan oil sector. Additionally, OFAC has amended General License 3 and … Continue Reading
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