The Treasury Department’s Office of Foreign Assets Control (OFAC) took action last Monday, November 8, 2021, and sanctioned a Latvia-based exchange, Chatex, its associated support network, and two ransomware operators for facilitating financial transactions for ransomware actors. In total, OFAC
Continue Reading OFAC Enforcement Impacts NFTs: As Crypto Enforcement Ramps Up to Combat Ransomware, Robust Compliance is Key
Prior COVID-19 Travel Bans Repealed as of November 8, 2021
On October 25, 2021, President Biden announced the suspension of the COVID-19 travel bans from Brazil, China, India, Iran, Ireland, the Schengen Area, South Africa, and the United Kingdom. Previously,
Continue Reading Sheppard Mullin Travel Checklist ‒ New Vaccination Travel Restrictions for Entry Into the United States: Air and Land Rules Effective November 8, 2021
Background
Last Friday, the Office of Foreign Assets Control (OFAC) published more targeted guidance for digital asset companies related to compliance with sanctions and best practices for mitigating risks. This guide comes on the heels of OFAC’s first enforcement action
Continue Reading Sanctions Compliance for Crypto: OFAC Issues Guidance Targeting Virtual Currency Industry
If your company is like many, your board of directors may be demanding that you put more effort into environmental, social, and governance issues, which have become known by the now-ubiquitous acronym “ESG.” Those demands don’t come from nowhere: consumers
Continue Reading Does Your Trade Policy Support Your Company’s Values?
Today, the United States Trade Representative issued a notice informing the importing community about a new Section 301 exclusion process and seeking comments from affected importers. The comment period begins on October 12, 2021, and ends on December 1, 2021.
Continue Reading Exclusions 2.0. The USTR Announces a New Section 301 Exclusion Process for Chinese Products
Companies are putting forth more effort, thought, commitment, and resources into environmental, social, and corporate governance (ESG) considerations across their business lines. The focus of ESG has primarily centered around climate change and sustainability, but the “S” in ESG is
Continue Reading ESG, Global Trade, and Forced Labor: Aligning Compliance with Company Values
Yesterday, the Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions on SUEX OTC, S.R.O, a cryptocurrency exchange, for its role in laundering money to ransomware attackers. According to OFAC, SUEX facilitated criminal transactions involving at least eight ransomware
Continue Reading First OFAC Sanctions Against a Cryptocurrency Exchange: Could the Designation of SUEX Signal an Enforcement Trend to Combat Cybercrime?
Internet platform providers rely upon developers of applications to populate their application stores. Some platform providers mandate app developers to use the platform’s in-app purchasing system as a condition to sell the apps on the platform. There have also been
Continue Reading Legislatures Can Free App Developers from Platform Providers’ Mandates to Use Their In-App Purchasing Systems Without Violating WTO Principles
This is the second of three articles on the Solar Industry and Forced Labor. Here we focus on interactions with solar module suppliers. Our first article in the series focused on regulations in this area, and our next will focus
Continue Reading Clean Energy’s Messy Problem II: The Solar Industry, I͟t͟s͟ S͟u͟p͟p͟l͟i͟e͟r͟s, and the Complex Task of Combatting Forced Labor
This is the first of three articles on the Solar Industry and Forced Labor. Here we focus on regulation. Articles in the coming weeks will focus on issues facing importers and their suppliers, and on investors and their requirements.
Continue Reading Clean Energy’s Messy Problem: The Solar Industry, the U.S. Government, and the Complex Task of Combatting Forced Labor
