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 April. Below is a summary of events this past quarter: About the document: This handy one-pager is designed to be used by our clients to provide a quick...
On April 22, 2024, the U.S. Department of Justice announced the indictment of 10 Venezuelan individuals for conspiring to violate the International Economic Emergency Powers Act (“IEEPA”). According to the DOJ, the individuals conspired to decade U.S. sanctions imposed on Petroleos de Venezuela S.A. (“PDVSA”) in January 2019. In April 2024, one of the defendants was arrested upon arrival at Miami’s internal Airport. The Violations...
In the absence of federal cybersecurity and data privacy laws, companies have to look to other sources of guidance, including industry standards, and state laws. The National Institute of Standards and Technology (“NIST”) has sought to fill some of the large gaps on the issue of cybersecurity. Enforcement agencies often cite the NIST Framework as an important barometer of an organization’s commitment to cybersecurity risks...
On April 19, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) published an interim final rule (“IFR”) that officially codifies certain changes to the Export Administration Regulations (“EAR”) precipitated by the United States’ participation in the Australia, United Kingdom, and United States (“AUKUS”) Trilateral Security Partnership. Announced in September 2021, AUKUS is intended to enhance the overall defense capabilities of each participating...
By: Daniela Melendez, Associate at The Volkov Law Group, and Alex Cotoia, Regulatory Compliance Manager. Daniela can be reached at [email protected] and Alex can be reached out at [email protected]. On April 15, 2024 Nicole Argentieri, Principal Deputy Assistant Attorney General and the Head of the U.S. Department of Justice’s (“DOJ’s”) Criminal Division, announced a new voluntary self-disclosure program for individuals complicit in certain types of organized...
El 17 de abril de 2024, la OFAC revocó formalmente el alivio de sanciones que anteriormente había proporcionado a la industria petrolera y de gas en Venezuela. Mediante la licencia 44 la OFAC había proporcionado un alivio de sanciones a Venezuela en condición de que el gobierno de Venezuela organizara unas elecciones libres y justas. Debido al incumplimiento del gobierno de Venezuela, la OFAC revocó...
On April 17, 2024, OFAC formally rolled back the sanctions relief it previously provided to the Venezuelan oil and gas industry. While OFAC provided the initial relief believing that Venezuela would permit a fair and open election, it appears that the Maduro regime has fallen short of its commitments. As such, and as part of its agreement with the beleaguered South American nation, OFAC has...
NAVEX continues to produce high-quality compliance reports, many of which are a must-read in the compliance industry. Its annual Whistleblower Report is of particular note — NAVEX is the leading provider of hotline services in the world and its data is invaluable as a source of trends in this industry. This year –2024 — is no exception. NAVEX combed through the data from 3784 organizations...
Remarks given by Commerce Secretary Gina Raimondo and Undersecretary Alan Estevez during the 2024 Policy Update Conference sponsored by the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) emphasized the need for organizations to enhance their due diligence efforts to prevent the diversion of restricted commodities to U.S. adversaries, including, but not limited to, the Russian Federation and the Islamic Republic of Iran. ...
OFAC is capable of extending a long-arm of enforcement, reaching sometimes non-U.S. companies that may “cause” another company to violate U.S. Sanctions laws. If you need to find an example of this long reach, look no further than last week’s OFAC settlement with SCG Plastics (“SCG”), in which SCG, a Thailand company, which sells plastic resins, agreed to pay $20 million for violations of the...
