On July 28, 2006, the Federal Financial Institutions Examination Council (FFIEC) released the 2006 Bank Secrecy Act/Anti-Money Laundering Manual ("BSA/AML Manual").
Client Alert | September 11, 2006
The United States Treasury Department announced today that Bank Saderat Iran will be denied even indirect access to the U.S. financial system, because of its efforts "to transfer money to terrorist organizations, including Hizballah, Hamas, the Popular Front for the Liberation of Palestine-General Command and Palestinian Islamic Jihad." Bank Saderat is one of the largest Iranian banks, with approximately 3,400 branch offices worldwide. Under the current rules, U.S.
Client Alert | September 8, 2006
The Office of Foreign Assets Control ("OFAC") has taken two recent actions related to transactions with countries and entities in the Middle East. On July 20, 2006, OFAC issued a Statement of Licensing Policy that establishes a favorable licensing regime through which U.S.
Client Alert | September 7, 2006
Partner Judith Lee and Of Counsel James Slear are authors of "Doing Business in China - Unique Corruption Compliance Concerns and Strategies" [PDF] published in August 2006 by the Washington Legal Foundation in their Contemporary Legal Note Series, No.
Client Alert | August 30, 2006
Effective August 17, 2006, the United States revoked all licenses and approvals authorizing the export of or other transfers of defense articles or services to Venezuela and will no longer authorize the export of such articles or services to Venezuela.
Client Alert | August 21, 2006
The Department of Defense (DoD) on August 14, 2006, published a proposed rule to amend the Defense Federal Acquisition Regulation Supplement (DFARS) to address requirements for preventing the unauthorized disclosure of export-controlled information and technology under DoD contracts.
Client Alert | August 14, 2006
On Monday, August 7, 2006, the Ninth Circuit reinstated a lawsuit brought by residents of Bougainville, Papua New Guinea (“PNG”) against London-based Rio Tinto PLC (“Rio Tinto”) under the Alien Tort Claims Act, 28 U.S.C.
Client Alert | August 10, 2006
The Office of Foreign Assets Control (OFAC) is under new leadership. On August 1, 2006, the U.S. Treasury Secretary Henry M. Paulson named Adam Szubin as the new Director of the Office of Foreign Assets Control OFAC.
Client Alert | August 3, 2006
On August 1, 2006, President Bush signed a bill renewing the Burmese Freedom and Democracy Act of 2003 (BFDA). This bill renews sanctions against Burma under the BFDA for an additional year and amends the BFDA to allow annual renewal of this law for up to six more years. The BFDA imposes a general import ban on products from Burma and bars investment in Burma.
Client Alert | August 2, 2006
The U.S. Department of Commerce recently proposed changes in export rules for the People’s Republic of China (the “PRC”). The proposed changes will purportedly loosen controls on many exports intended for civil end-use while tightening restrictions on exports that may contribute to the PRC’s military capabilities.
Client Alert | July 19, 2006
On May 15, 2006, the United States Department of State announced an arms embargo against Venezuela, identifying that country as not fully cooperating with U.S.
Client Alert | June 8, 2006
In a May 15, 2006 announcement, the Bush Administration signaled Libya's removal from the list of countries not supporting U.S. antiterrorism efforts and the reopening of diplomatic relations with Libya.
Client Alert | June 8, 2006
Effective May 10, 2006, OFAC amended its Global Terrorism Sanctions Regulations, Terrorism Sanctions Regulations and Foreign Terrorist Organizations Sanctions Regulations to add general licenses (referred to below as "the May 10 amendments") authorizing certain transactions with the Palestinian Authority (PA).
Client Alert | May 17, 2006
In a case that demonstrates the risks associated with the cross-utilization of even minor components in military and commercial applications, a major aerospace company recently agreed to pay $15 million to settle allegations that it violated the Arms Export Control Act ("AECA"), as implemented by the International Traffic in Arms Regulations ("ITAR").
Client Alert | April 17, 2006
The Office of Foreign Assets Control ("OFAC") has recently taken four actions of potential interest to companies participating in international exports:First, OFAC recently codified the Syrian sanctions regulations that had been imposed by a 2004 Executive Order.Second, President Bush has just issued an Executive Order imposing sanctions against the Cote d'Ivoire.Third, the Federal Register has published OFAC's new Economic Sanctions Enforcement Procedures for Banking Institutions.Fourth, the U.S.
Client Alert | March 17, 2006
On January 27, the Act to End Atrocities and Terrorism in the Sudan, Public Act 094-0079 ("the Act"), will become effective in Illinois. This legislation amends the Illinois Deposit of State Moneys Act to prohibit the investment of state funds in Sudanese entities and in domestic companies who do business with Sudan.
Client Alert | January 26, 2006
Brussels Associate Vassili Moussis is co-author of "Leniency for Japan" [PDF] in the December 2005/January 2006 edition of Global Competition Review. Reprinted with permission.
Article | January 17, 2006
November 2005Partners Joseph West and Judith Lee and associate Jason Monahan are authors of "U.S. Export Control Compliance Requirements for Government Contractors" [PDF] published in the November 2005 issue of Briefing Papers, a Thomson/West publication.Reprinted with permission, Briefing Papers, © 2005 Thomson/West.
Client Alert | November 30, 2005