Category: Archive

Archive | Policy Advisory

OFAC’s Amazon Penalty Highlights Need for Human Touch

On July 8, 2020, Treasury’s Office of Foreign Assets Control (OFAC) settled with with Amazon.com, Inc. over the company’s potential civil liability for its likely violations of US sanctions. The tech giant has agreed to pay $134,523 to settle allegations that it provided goods and services to individuals in Crimea, Syria, and Iran.

Read more

Archive | Policy Advisory

Xinjiang Supply Chain Business Advisory Warns US Firms of Regulatory and Reputational Risks

Click here for PDF On July 1, 2020, the Departments of Commerce, Homeland Security, State, and Treasury published an advisory describing the “risks and considerations for businesses with supply chain exposure to entities engaged in forced labor and other human rights abuses in Xinjiang.” The advisory—an effort to help mitigate reputational, economic, legal, and other …

Read more

Archive | Profile

Miami Attorney Acts as Gatekeeper for Maduro Regime Insiders

Executive Summary A Miami attorney almost certainly acts as a facilitator for entities and individuals with ties to Venezuela’s Maduro regime. The individual has not been investigated for or charged with knowingly participating in or facilitating unlawful activity, likely because he removes himself as registered agent or attorney of record before these individuals and entities …

Read more

Archive | Policy Advisory

Guidance to Address Illicit Shipping and Sanctions Evasions Practices

Click here for PDF On 14 May 2020, the Treasury and State Departments, along with the US Coast Guard issued a joint Guidance to Address Illicit Shipping and Sanctions Evasions Practices. This document provides updated sanctions guidance for maritime, energy, metals, and related industries and identifies US compliance expectations for firms in these fields.

Read more

Archive | Policy Alert

Bureau of Industry and Security Lists 33 Chinese Entities

Click here for PDF On June 5, 2020, the Bureau of Industry and Security (BIS) released details on 33 Chinese entities—including government agencies, state-sponsored research institutes, universities and affiliated firms, as well as private companies involved in the general supply chain—it is adding to its Entity List, imposing stricter regulations on exports, reexports, and transfers …

Read more

Archive | Policy Alert

Uyghur Human Rights Policy Act of 2020

Click here for PDF On 14 May, the US Senate approved the Uyghur Human Rights Policy Act of 2020. This legislation directs the President to impose sanctions against those responsible for human rights violations and abuses against Turkic Muslim ethnic minorities in Xinjiang Uyghur Autonomous Region. The bill also:

Read more