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International Compliance Blog

US Requires Negative COVID Tests or Proof of Recovery for all International Air Travelers; Biden Expected to Reinstate Travel Suspension Proclamation

By Liz LaRocca & Dana Delott

January 20, 2021

From the outset of the COVID-19 pandemic, the United States has issued a series of restrictions on entry to the country. The latest restriction, effective January 26, 2021, mandates proof of a negative COVID-19 test or proof of recovery from COVID prior to boarding any flight to the United States. As set forth below, it differs from the existing patchwork of COVID-related travel restrictions, in that it applies to all travelers age two or older–including…

International Compliance Blog

US Sanctions Parties Involved in Nord Stream 2 Pipeline Project

By Peter Jeydel & Cherie Tremaine

January 20, 2021

On January 19, 2021, the US State Department announced the imposition of sanctions on Russia-based entity KVT-RUS and Russian-flagged vessel FORTUNA pursuant to Section 232 of the Countering America’s Adversaries Through Sanctions Act (CAATSA), for “knowingly selling, leasing, or providing to the Russian Federation goods, services, technology, information, or support for the construction of Russian energy export pipelines.” Accordingly, KVT-RUS and the vessel FORTUNA have been added to OFAC’s SDN list. The State Department also…

International Compliance Blog

UK Government Announces New Measures to Combat Forced Labour and Human Rights Abuses in Xinjiang

By Alexandra Melia & Yas Froemel

January 19, 2021

On 12 January 2021, UK Foreign Secretary, Dominic Raab, announced a package of measures intended to ensure that British organisations in the public and private sector are not complicit in – or profiting from – human rights violations against Uyghur Muslims in China’s Xinjiang region. The UK has worked in coordination with the Canadian government on the new measures, which were introduced in response to growing evidence of gross human rights violations, including extra-judicial detention…

International Compliance Blog

Updated: Amended Executive Order Makes Clear US Persons Must Divest Securities of Chinese Military Companies as Defense Department Identifies Nine More Entities

By Nicholas Turner, Wendy Wysong, Ed Krauland, Brian Egan, Jack Hayes & Meredith Rathbone

January 15, 2021

On January 14, 2021, the White House issued an Executive Order (EO) to amend EO 13959 of November 12, 2020, which prohibits US persons from transacting in securities related to so-called “Communist Chinese military companies” (CCMCs). The amended EO 13959 makes clear that US persons must divest their holdings in such securities within designated wind-down periods, after which possessing the securities will also be prohibited. For CCMCs identified in the Annex to EO 13959, on…

International Compliance Blog

OFAC Asserts Jurisdiction over French Bank’s Internal Transfers and Foreign Exchange Transactions

By Peter Jeydel, Jack Hayes & Brian Egan

January 15, 2021

OFAC’s January 4, 2021 civil settlement with France-based Union de Banques Arabes et Françaises (“UBAF”) provides another case study of the agency’s expansive view of its jurisdiction over transactions occurring outside the United States, when the US financial system is involved even indirectly. This case is particularly noteworthy coming after OFAC’s recent settlement with British Arab Commercial Bank, which we previously analyzed. A key lesson from the UBAF settlement is that OFAC’s jurisdiction may…

International Compliance Blog

European Commission issues Guidance Note on the EU Global Human Rights Sanctions Regime

By Stefan Tsakanakis, Guy Soussan, Simon Hirsbrunner & David O'Sullivan

January 14, 2021

Following the adoption of the EU Global Human Rights Sanctions Regime, which is set out in Council Regulation (EU) 2020/1998 and Council Decision (CFSP) 2020/1999 (see our previous client alert), the European Commission published a Guidance Note on the implementation of certain provisions under Council Regulation (EU) 2020/1998. The stated aim of the Guidance Note is to address the questions most likely to arise in the application of the new restrictions and to ensure…

International Compliance Blog

United States v. Ho

By Lucinda Low, Patrick Linehan, Jack Hayes & Nicholas Kimbrell

January 14, 2021

In late December, the United States Court of Appeals for the Second Circuit affirmed the conviction of Chi Ping Patrick Ho on seven counts alleging multiple FCPA and money laundering (and related conspiracy) violations.[1] The decision is notable for its construction of various FCPA provisions, and further demonstrates the expansive jurisdictional reach of anti-money laundering laws to dollar-denominated transfers. Ho, a citizen of Hong Kong, served as an officer and director of the Hong…

International Compliance Blog

Ten Key Takeaways from the NDAA’s AML Reforms

By Brian Egan, Jack Hayes & Evan Abrams

January 13, 2021

On January 1, 2021, the United States enacted the National Defense Authorization Act for Fiscal Year 2021 (“NDAA”) after the US House of Representatives and US Senate voted to override a presidential veto of the law. Included within the NDAA are a significant number of provisions related to anti-money laundering (“AML”) and countering the financing of terrorism (“CFT”), including provisions reforming the Bank Secrecy Act (“BSA”), a collection of statutes underpinning most of the current…

International Compliance Blog

Congress Continues to Push for Key US Export Controls Authorization for Israel

By Peter Jeydel

January 11, 2021

In a little-noticed provision of the annual US military authorization law, which took effect on January 1, 2021, the US Congress issued yet another push for the US Commerce Department to grant eligibility to Israel for a key authorization under US export controls. Israeli companies in the tech, aerospace/defense, and other sectors that are regulated under military and “dual-use” (i.e., military/commercial) export controls should watch these developments closely and consider engaging with the US government…

International Compliance Blog

New Executive Order targets Chinese connected software applications

By Wendy Wysong, Ali Burney, Meredith Rathbone, Hena Schommer, Jack Hayes & Peter Jeydel

January 7, 2021

In another attempt to impose restrictions on Chinese technology companies in the final days of his presidency, on January 5, 2021, Trump issued a new Executive Order (EO) “Addressing the Threat Posed By Applications and Other Software Developed or Controlled By Chinese Companies.” The EO, which was issued pursuant to the International Emergency Economic Powers Act, authorizes the imposition of restrictions, on or after February 19, 2021, against eight popular Chinese connected software…

International Compliance Blog

Blog Authors

US Requires Negative COVID Tests or Proof of Recovery for all International Air Travelers; Biden Expected to Reinstate Travel Suspension Proclamation

US Sanctions Parties Involved in Nord Stream 2 Pipeline Project

UK Government Announces New Measures to Combat Forced Labour and Human Rights Abuses in Xinjiang

Updated: Amended Executive Order Makes Clear US Persons Must Divest Securities of Chinese Military Companies as Defense Department Identifies Nine More Entities

OFAC Asserts Jurisdiction over French Bank’s Internal Transfers and Foreign Exchange Transactions

European Commission issues Guidance Note on the EU Global Human Rights Sanctions Regime

United States v. Ho

Ten Key Takeaways from the NDAA’s AML Reforms

Congress Continues to Push for Key US Export Controls Authorization for Israel

New Executive Order targets Chinese connected software applications

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