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Category Archives: Sanctions, Trade Embargo, and Export Controls

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Compliance, Sanctions, Trade Embargo, and Export Controls

Latest US Sanctions Against Russia Target Financial Services and Energy Sector

On Wednesday, July 16, 2014, the United States announced additional sanctions against Russian interests in response to the continuing crisis in Ukraine. Starting in March of this year, the United States began imposing sanctions against Russian organizations and individuals, including a number of individuals associated with President Vladimir Putin’s inner circle. This latest round of… Continue Reading
Enforcement and Prosecution Policy and Trends, Sanctions, Trade Embargo, and Export Controls

Violations of the ITAR, EAR or OFAC Regulations: Mistake or Willful Act?

The laws regarding what can be exported from the U.S. and where those exports can go are complex. Not surprisingly, these laws are violated on occasion. When violations occur, the critical question for enforcement agencies is whether the violations were willful. The answer to that question generally determines whether the violation is treated as a… Continue Reading
Election and Political Law, Enforcement and Prosecution Policy and Trends, Sanctions, Trade Embargo, and Export Controls

The Bedeviling Question of Willfulness in the Criminal Context

Courts have long struggled with interpreting (and thus instructing a jury on) the statutory element of willfulness. This frequently manifests in the challenge of expressing what level of knowledge the defendant must possess about the law he is accused of violating. Reflective of this challenge, courts have characterized the element of willfulness as “bedeviling,” turning… Continue Reading
Compliance, Enforcement and Prosecution Policy and Trends, Sanctions, Trade Embargo, and Export Controls

As Companies Wind Down in Iran, the President Must Roll Up his Investigative Sleeves

As we know, the recently enacted Iran Threat Reduction and Syria Human Rights Act of 2012 (ITRSHRA) expands the reach of the U.S. sanctions program and imposes new SEC disclosure requirements on issuers if they or their affiliates do business with Iran (although, their affiliates may not have violated U.S. law in any way, because… Continue Reading
Sanctions, Trade Embargo, and Export Controls

The Continued Push for the National Export Initiative and Export Control Reform

Secretary of Commerce Gary Locke continued the administration’s push to boost U.S. exports 100% by 2015 in accordance with President Obama’s 3/11/10 executive order establishing the National Export Initiative (“NEI”).  Last week, Secretary Locke addressed the 2010 International District Export Council (“DEC”) at a conference in Detroit, noting recent economic successes as a result of the NEI… Continue Reading
Sanctions, Trade Embargo, and Export Controls

Implementation of New Iran Sanctions Act Begins

In recent years, the U.S. government has vigorously pursued financial institutions that knowingly violated sanctions targeting rogue regimes.  Since January 2009, the Department of Justice and the Treasury’s Office of Foreign Assets Controls (“OFAC”) have brought a series of actions against European banks for violating U.S. financial sanctions.  Four banks have paid criminal penalties totaling… Continue Reading
Sanctions, Trade Embargo, and Export Controls

KSM Trial in Political Limbo?

It’s been more than several weeks since the Administration indicated that a decision on whether Khalid Sheikh Mohammed will be tried in a federal court or military commission was weeks away. Of course, this will be the second decision on the issue – Attorney General Eric Holder first announced that KSM and his 9/11 co-conspirators would… Continue Reading

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