In a recent proposed rule, the Department of Commerce has taken additional steps toward imposing significant regulations on infrastructure as a service (IaaS) providers, including providers engaged in training certain large AI models. The notice of proposed rulemaking (NPRM
International Compliance Blog
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BIS Makes Further Changes to Administrative Enforcement, But Questions Remain
On January 16, 2024, the Assistant Secretary for Export Enforcement at the Department of Commerce’s Bureau of Industry and Security (BIS) issued a memorandum, announcing that:
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Beneficial Ownership Reporting Requirements Under the Corporate Transparency Act Are Now In Effect
As of January 1, 2024, the Corporate Transparency Act (CTA) is effective, impacting millions of entities. On September 30, 2022, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) published a final rule to implement the beneficial ownership…
The Top Ten Asia-Pacific FCPA Enforcement Actions of 2023
Enforcement of the Foreign Corrupt Practices Act (FCPA) in 2023 has been described as a lull, a continued downward trend, or a slump, but that may be “bullsh*t,” to quote an FCPA academic. However they are described, the 2023 FCPA…
New Secondary Sanctions Target Non-US Banks That Engage in Transactions with Russia’s Military-Industrial Base
On December 22, 2023, President Biden issued a new Executive Order (“EO”) 14114 “Taking Additional Steps With Respect to the Russian Federation’s Harmful Activities” which amended EOs 14024 and 14068. These amendments introduce the authority to impose secondary sanctions with…
UK’s Department for Business & Trade Issues New General Trade Licence for Third-Country Processed Iron and Steel Measures
On December 11, 2023, the UK’s Department for Business & Trade (“DBT”) published a General Trade Licence of indefinite duration concerning measures related to third-country processed iron and steel, pursuant to The Russia (Sanctions) (EU Exit) Regulations 2019 (the “Russia…
UK Issues New Package of Russia Financial and Trade Sanctions
On December 14, 2023, the UK government issued new Russia sanctions legislation under The Russia (Sanctions) (EU Exit) (Amendment) (No.4) Regulations 2023 (“Amendment No. 4”) and The Russia (Sanctions) (EU Exit) (Amendment) (No.5) Regulations 2023 (“Amendment No. 5”). The new…
New UK Iran Sanctions Regime Comes into Force
On December 14, 2023, a new UK Iran sanctions regime originally announced in July 2023 came into effect as The Iran (Sanctions) Regulations 2023 (“New Iran Regulations”) and The Iran (Human Rights) (EU Exit) Regulations 2019 (“Iran Human Rights Regulations”)…
UK Publishes Red Alert on Sanctions Evasion, Makes New Designations, and Announces the Creation of Trade Sanctions Civil Enforcement Body
On December 6, 2023, the UK’s National Economic Crime Centre (“NECC”) issued a red alert concerning the export of high-risk goods that Russia is using on the battlefield in Ukraine. The red alert outlines sanctions evasion red flags for the…
FinCEN Proposed Rule Targets Digital Asset Mixers
On October 19, 2023, the U.S. Department of the Treasury’s (“Treasury”) Financial Crimes Enforcement Network (FinCEN) announced a Notice of Proposed Rulemaking (NPRM) that would implement new recordkeeping and reporting requirements on domestic financial institutions and domestic financial agencies, related…