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Sylvia Yi

You are reading Bass, Berry & Sims’ enforcement roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox every month.

To stay up to date, subscribe to our GovCon & Trade blog. If you have questions about any of the actions mentioned and how they relate to your business, contact our firm’s international trade team. We welcome your feedback and encourage sharing this newsletter with anyone interested.

January saw a bevy of interesting enforcement actions and regulatory policy changes. A high-level former FBI agent was charged with sanctions violations, for the first time ever a North Korean national was extradited to the U.S. for money laundering to benefit designated persons, and yet another instance of Chinese espionage was thwarted. Let’s jump in!Continue Reading International Trade Enforcement Roundup – January 2023

You are reading Bass, Berry & Sims’ new enforcement roundup, where we bring notable enforcement actions, policy changes, interesting news articles and a bit of our insight to your inbox every month.

To stay up to date, subscribe to our GovCon & Trade blog. If you have questions about any of the actions mentioned and how they relate to your business, contact our firm’s international trade team. We welcome your feedback and encourage sharing this newsletter with anyone who may be interested.

December was a busy month! A highly complex Russian procurement network dismembered, a former Marine indicted, a government contractor sentenced to prison for export violations, and temporary denial orders (TDOs) galore! Let’s get into it.Continue Reading International Trade Enforcement Roundup – December 2022

The Bass, Berry & Sims international trade team continues to monitor U.S. government action in response to Russia’s invasion of Ukraine. In the final months of 2022, the U.S. government added multiple individuals and entities to the Specially Designated Nationals (SDN) List and the Entity List (EL), froze assets of individuals, issued or revised general licenses, and took enforcement action against individuals and companies. This post summarizes new U.S. sanctions and export restrictions as of Friday, December 30. This post supplements our previous summaries, which are available by following the links at the end of this blog post.

Department of the Treasury and Department of State Designations

On December 22, the Department of the Treasury, Office of Foreign Assets Control (OFAC), in consultation with the Department of State, added 10 entities associated with the Russian Navy and/or the Russian maritime industry to the SDN List.Continue Reading Russia, Ukraine: Update as of Friday, December 30

You are reading Bass, Berry & Sims’ new enforcement roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox every month.

To stay up to date, subscribe to our GovCon & Trade blog. If you have questions about any of the actions mentioned and how they relate to your business, contact our firm’s international trade team. We welcome your feedback and encourage sharing this newsletter with anyone interested.

Following an active October, enforcement actions and regulatory policy changes slowed in November. With that said, the actions taken in November involved some novel topics and provide several insights to glean.Continue Reading International Trade Enforcement Roundup – November 2022

You are reading Bass, Berry & Sims’ new enforcement roundup, where we bring notable enforcement actions, policy changes, interesting news articles and a bit of our insight to your inbox every month.

October 2022 was an active month for enforcement, with the Department of Treasury updating Committee on Foreign Investment in the United States (CFIUS) guidelines and the Departments of Justice (DOJ) and Commerce (DOC) taking multiple actions. To stay up to date, subscribe to our GovCon & Trade blog. If you have questions about any of the actions mentioned and how they relate to your business, contact our international trade team. We welcome your feedback and encourage sharing this newsletter with anyone who may be interested.Continue Reading International Trade Enforcement Roundup – October 2022

The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and export restrictions as of Monday, October 3. This post supplements our previous summaries, which are available by following the links at the end of this blog post.

Commerce Adds Iranian Aircraft to List of Aircraft Operated in Violation of the EAR

On September 19, the Commerce Department’s Bureau of Industry and Security (BIS) updated its growing list of aircraft that have flown into Russia and/or Belarus in apparent violation of the Export Administration Regulations (EAR). As discussed previously, these aircraft are essentially off limits for any person to service (or operate), given that nearly any dealing with respect to such an aircraft would violate General Prohibition 10 of the EAR.Continue Reading Russia, Ukraine: Update as of October 3

The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and export restrictions as of Tuesday, August 9. This post supplements our previous summaries, which are available by following the links at the end of this blog post.

Treasury Targets Broad Range of Entities in Recent Round of Sanctions

On August 2, acting pursuant to Executive Order 14024, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) announced sanctions designating members of the Russian elite, a multinational corporation, and sanctions evaders.Continue Reading Russia, Ukraine: Update as of August 9

The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and export restrictions as of Thursday, July 7. This post supplements our previous summaries, which are available by following the links at the end of this blog post.

Commerce Department Continues to Target Airlines, Entities; OFAC Extends Sanctions to New Parties, Imports of Gold

On June 24, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) issued Temporary Denial Orders (TDOs) against an additional three Russian airlines: Nordwind Airlines, Pobeda Airlines, and S7 Airlines. BIS cited apparent ongoing violations of the comprehensive export controls imposed on Russia. Under these TDOs, the airlines are banned from participating in transactions subject to the Export Administration Regulations (EAR), including exports from the United States and re-exports from abroad. The TDOs initially run for 180 days but will likely be extended.Continue Reading Russia, Ukraine: Update as of July 7

The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and export restrictions as of Monday, June 6. This post supplements our previous summaries, which are available by following the links at the end of this blog post.

Commerce Department Issues Final Rule Refining the Export Administration Regulations and Improving Transparency in Export Enforcement Cases

EAR Amendments and Clarifications

On June 2, the U.S. Commerce Department, Bureau of Industry and Security (BIS) issued a final rule refining certain provisions of the Export Administration Regulations (EAR).

Several portions of the rule expand and refine the EAR restrictions related to Russia and Belarus.Continue Reading Russia, Ukraine: Update as of June 6

The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and export restrictions as of Wednesday, June 1. This post supplements our previous summaries, which are available by following the links at the end of this blog post.

Commerce Department Issues Temporary Denial Order against Rossiya, the Fifth Russian Airline to Face Export Restrictions

On May 20, the U.S. Commerce Department, Bureau of Industry & Security (BIS) issued a temporary denial order (TDO) against Rossiya citing ongoing violations of the comprehensive U.S. export controls imposed on Russia. Rossiya is headquartered in St. Petersburg and, according to BIS, has operated multiple U.S.-origin aircraft subject to the Export Administration Regulations (EAR) into and out of Russia without the required BIS authorization.Continue Reading Russia, Ukraine: Update as of June 1