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.

Click here to download the quarterly update for July.

Below is a summary of events this past quarter:

• Significantly increased threat of secondary sanctions with regards to a large number of Russian entities. Addition of “Secondary sanctions risk: See Section 11 of Executive Order 14024” notation to several SDN List entries. OFAC has already exercised these powers on certain Chinese 
• Statute of limitations for civil violations of OFAC sanctions extended to 10 years.
• OFAC continues to upgrade its technical infrastructure, including updates to its sanctions list search service and the licensing portal. The licensing portal now provides additional information relating to status of license requests.
• As tensions in the Middle East increase, expect additional sanctions and export control activity related to the region.
• Considering the issues surrounding the Venezuelan elections, expect sanctions to continue for the foreseeable future, and potentially increase.
• Certain export controls have been relaxed, including those relating to certain cameras, systems, and related components

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.

If you would like to be on the distribution list going forward, please email Matt Stankiewicz at [email protected]. And if you have any further questions, please reach out!