Quarterly Trade Compliance Update – January 2024
Each quarter, we send many of our clients a quarterly trade compliance update, highlighting important developments over the last few months and summarizing key points for important sanctions programs.
Below is a summary of events this past quarter:
- OFAC has already begun to roll back some of the sanctions relief it provided to Venezuela. Transactions with CVG Minerven will again be prohibited, and the company is currently subject to a wind down period ending February 13th.
- Continued increase in sanctions and export controls on Russia. Newly published Executive Order 14114 creates secondary sanctions risks for foreign financial institutions.
- Significant focus on the Russian crude oil price cap with publication of Quint-Seal Compliance Note re: Know-Your-Cargo, a Maritime Oil Industry Advisory, and designation of various vessels and related entities.
- Additional focus on Russia’s military procurement network throughout the world.
Middle East –
- Conflict in the region has led to additional designations, restrictions, and enforcement of antiboycott regulations. Expect this trend to increase dramatically as tensions continue to escalate.
- BIS announces various enhancements to its voluntary self-disclosure process.
- FinCEN and BIS announce new reporting key term and highlight red flags relating to global evasion of U.S. Export Controls
- Commerce proposes rule to advance U.S. national security interests and implement Biden-Harris Administration’s AI Executive Order and National Cybersecurity Strategy.
About the document:
This handy one-pager is designed to be used by our clients to provide a quick reference guide for the complex topics of trade sanctions and export control regulations. The goal is to briefly summarize key points for each program.
This document can be especially useful for non-lawyers and non-compliance officers. Some of our clients distribute the document to the sales and operations teams, or hang it with other legal and compliance material somewhere in the office. Many front-line employees need to know enough about sanctions to identify red flags and then engage legal and compliance as needed. We’ve unfortunately seen unwitting violations due to a lack of education or a lack of reference materials.