Treasury’s Office of Foreign Assets Control (OFAC) sanctioned over 20 individuals and entities for their involvement in financial facilitation networks for the benefit of Iran’s Ministry of Defense and Armed Forces Logistics and Iranian Armed Forces General Staff, and the Islamic Revolutionary Guard Corps-Qods Force.  

Treasury’s Office of Foreign Assets Control (OFAC) sanctioned three entities and blocked three vessels that used Price Cap Coalition services while carrying Russian crude oil above the Coalition-agreed price cap.   The vessels NS Champion, Viktor Bakaev, and HS Atlantica used U.S.-person services while carrying Russian Urals crude priced above $70 per barrel after the price cap took effect

As the Department of Energy sets to distributing $6 billion from the Infrastructure Investment and Jobs Act,  to support domestic battery material processing, manufacturing, and recycling,  the Department is required prioritize material processing and manufacturing applicants that will not use battery material supplied by or originating from a “foreign entity of concern” (FEOC). Recognizing that it may be difficult to definitively evaluate the contractual relationships of upstream suppliers, DOE is also considering whether to provide entities with the opportunity to voluntarily request a review of contracts and licensing arrangements by DOE in order to provide additional certainty regarding whether effective control by a FEOC is present.

FinCEN joined twelve financial intelligence units (FIUs) in issuing a public statement November 27, recognizing the formation of a task force of like-minded FIUs who aim to strengthen efforts to disrupt international financial flows to Hamas and other terrorist organizations.

The Financial Crimes Enforcement Network (FinCEN) issued a final rule Nov 29 that extends the deadline for certain reporting companies to file their initial beneficial ownership information (BOI) reports with FinCEN. Reporting companies created or registered in 2024 will have 90 calendar days from the date of receiving actual or public notice of their creation or registration becoming effective to file their initial reports.

Commerce Secretary Gina Raimondo announced plans to create an Export Control Advisory Panel “to help us get our export controls to be more effective by having a continuous engagement with industry.”   The announcement was included in her remarks to the Fall meeting of the President’s Export Council (PEC) November 29th which included a recap of AI initiatives and the announcement of a mission to the ASEAN region in March.

Co-Chairs of the Digital Trade Caucus, led a bipartisan letter with 38 members of Congress urging U.S. Trade Representative Katherine Tai to reconsider her agency’s decision to abandon important bipartisan digital trade proposals at the World Trade Organization. Suzan DelBene (D-WA) and Darin LaHood (R-IL) contend the decision to walk away from key digital trade proposals runs counter to the interests of American workers and businesses, while ceding more leverage to foreign powers, like the People's Republic of China (PRC), to write the rules that will govern the global digital economy for years to come.

US Trade Representative Katherine Tai announced  that the United States has asked Mexico to review whether workers at the Autoliv Steering Wheels Mexico facility in El Marqués in the state of Quéretaro are being denied the right to freedom of association and collective bargaining. Allegations against the Swedish airbag giant include firing workers in retaliation for union activity, making coercive statements that interfere with workers’ rights and denying access to the facility for union-related activity.

This briefing paper on dual-use and cyber-surveillance provides on overview of current EU export controls of dual-use items in general and cyber-surveillance items in particular, and what the approach is in countries such as the US, the UK and Japan. It explains the impact of the sanctions against Russia on the export of dual-use items and the use of cyber-surveillance in the conflict in the Ukraine.

Two Texas men were convicted at trial on Nov. 15 on charges of attempting to violate the International Emergency Economic Powers Act (IEEPA), conspiracy to violate IEEPA, and conspiracy to commit money laundering in connection with their attempt to transact in sanctioned Iranian petroleum and launder the proceeds. According to evidence presented at trial, in 2019 and early 2020, Zhenyu “Bill” Wang and Daniel Ray Lane engaged in a conspiracy to purchase petroleum from Iran, in violation of economic sanctions imposed by the United States under IEEPA. They then planned to mask the origins of the petroleum and sell it to a refinery in China. The defendants also attempted to conceal their illegal transactions by obtaining foreign passports, engaging in sham contractual agreements, and conspiring to launder the proceeds of the sale through shell entities and offshore financial accounts.

Two U.K.-based reinsurance brokers have agreed to resolve investigations by the Justice Department into violations of the Foreign Corrupt Practices Act (FCPA) arising from a corrupt scheme to pay bribes to Ecuadorian government officials.  Tysers and H.W. Wood each entered into a three-year deferred prosecution agreement (DPA) with the department in connection with a criminal information filed in the Southern District of Florida charging both companies with conspiracy to violate the anti-bribery provisions of the FCPA. 

Binance Holdings Limited (Binance), the entity that operates the world’s largest cryptocurrency exchange,, pleaded guilty and has agreed to pay over $4 billion to resolve the Justice Department’s investigation into violations related to the Bank Secrecy Act (BSA), failure to register as a money transmitting business, and the International Emergency Economic Powers Act (IEEPA) Binance’s founder and chief executive officer (CEO), Changpeng Zhao, a Canadian national, also pleaded guilty to failing to maintain an effective anti-money laundering (AML) program, in violation of the BSA and has resigned as CEO of Binance.

All but three Republican Senators sent a letter to Secretary of Commerce Gina Raimondo raising questions over the decision  to pause for 90 days the issuance of export licenses for firearms, ammunition, and certain accessories to most overseas markets  The letter notes the impact this pause could have on “U.S. commercial and economic interests” which according to the firearms and ammunition industry has an estimated “direct cost of at least $89 million associated with the 90 day pause and at least $238 million annually should the pause become permanent.”

The Regulations and Procedures Technical Advisory Committee (RPTAC) will meet December 12, 2023, 9:00 a.m., Eastern Standard Time, in the Herbert C. Hoover Building, Room 3884, 1401 Constitution …

The Treasury Department’s Office of Foreign Assets Control is imposing sanctions on three entities and identifying as blocked property three vessels that carried Russian crude oil above the price cap agreed to by the United States and its allies. “Shipping companies and vessels participating in the Russian oil trade while using Price Cap Coalition service providers should fully understand that we will hold them accountable for compliance,” Treasury Deputy Secretary Wally Adeyemo.

 In a concerted effort to combat the import of clothing and textiles made with forced labor, a bipartisan group of U.S. Senators have urged U.S. Customs and Border Protection (CBP) to intensify oversight and enforcement measures. The Senators addressed their concerns to Acting CBP Commissioner Troy Miller, highlighting the necessity of enforcing the Dominican Republic-Central American Free Trade Agreement (CAFTA-DR) and the United States-Mexico-Canada Agreement (USMCA).

On November 16, 2023, the U.S. Department of Justice (DOJ) issued a letter to Lifecore Biomedical, Inc., formerly known as Landec Corporation, under the agency's Foreign Corrupt Practices Act (FCPA) Corporate Enforcement Policy. This letter was a "declination with disgorgement," [link] indicating that the DOJ decided not to prosecute Lifecore despite identified misconduct. The situation involved FCPA violations by Lifecore’s former subsidiary, Yucatan Foods. It was found that employees and agents of Yucatan Foods had engaged in bribery, specifically paying bribes to Mexican government officials to secure a wastewater discharge permit.

As Nicaraguan President Daniel Ortega continues his four decade devolution  from radical chic hero of the revolution to Somoza-style latin despot, the Biden Administration renewed the Trump-era  restrictions on travel and property ownership by Ortega and his cadre.

Aircraft parts suppliers to the Maduro Regime and Indian semiconductor distributors trading with Russia were the subject of regulatory actions last week, while Uncle Xi's promise of help with our Fentanyl problem got a state forensic lab off the blacklist.

The  OFAC-OFSI Enhanced Partnership , UK Office of Financial Sanctions Implementation (OFSI) and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) marked  …

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