United States Departments of Treasury, Commerce, and Justice Issue “Tri-Seal” Compliance Note on Voluntary Self-Disclosure of Potential Violations

On Wednesday, July 26, 2023, the United States Department of Justice, Department of Commerce’s Bureau of Industry and Security (“BIS”), and Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a tri-seal compliance note (the “Note”) focusing on the voluntary self-disclosure policies that apply to U.S. sanctions, export controls, and other national security … Read more

Humanitarian Relief Efforts Related to the Earthquakes in Turkey and Syria

On February 6, 2023, powerful earthquakes devastated Turkey and Syria. Media reports indicate that the first earthquake, “which hit near the town of Gaziantep, was closely followed by numerous aftershocks – including one quake which was almost as large as the first.” The destruction caused by these earthquakes has toppled thousands of buildings, killed and … Read more

OFAC Designates Board of Directors of Iranian UAV Manufacturer as SDNs

On February 3, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced sanctions on eight senior executives of Paravar Pars Company (Paravar Pars), an Iran-based firm that was previously sanctioned by the United States and European Union for manufacturing Shahed-series unmanned aerial vehicles (UAVs) for Iran’s Islamic Revolutionary Guard Corps … Read more

OFAC Releases New Iran Internet Guidance

On January 11, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a new Iran-related “Frequently Asked Question” (“FAQ”) (available here) regarding the implementation of Iran General License (“GL”) D-2, issued by OFAC on September 23, 2022.  In addition to this new FAQ, OFAC also amended over twenty already published … Read more

BIS Releases FAQs on the Interim Advanced Computing Rule Regarding Advanced Computing and Semiconductor Manufacturing Items

On October 7, 2022, the United States Department of Commerce’s Bureau of Industry and Security (“BIS”) issued an Interim Advanced Computing Rule (“IACR”) targeting exports related to advanced computing integrated circuits and related commodities to the People’s Republic of China (“China”). The IACR also contains additional restrictions on semiconductor manufacturing and interactions with semiconductor manufacturing … Read more

U.S. Equipment Distributor Pays $140,000 on 14 Felony Counts of Failure to File Export Information

Last week, the United States Department of Justice (“DOJ”) announced the sentencing of Intertech Trading Corporation (“Intertech”) on fourteen felony counts under 13 U.S.C. § 305 for failure to file export information regarding shipments of “lab equipment” to both Russia and Ukraine. The DOJ initially brought these charges against Intertech in June 2022, and Intertech … Read more

BIS Implements Sweeping New Export Controls Targeting China

On October 7, 2022, the Department of Commerce’s Bureau of Industry and Security (“BIS”) took two significant actions with major implications for companies and persons dealing with the Chinese semiconductor and electronics sectors: BIS issued an interim final rule (the “IFR”) targeting exports to the People’s Republic of China that, among other things, imposes sweeping … Read more

OFAC, BIS Release New Russia Sanctions and Export Control Alert

Illustrating the trend of coordinated sanctions actions taken by the Treasury and Commerce Departments, last week the Office of Foreign Assets Control (“OFAC”) worked in tandem with the Commerce Department Bureau of Industry and Security to publish an Alert entitled, “OFAC-BIS Alert: Impact of Sanctions and Export Controls on Russia’s Military-Industrial Complex,” which discusses the … Read more