Cross-Border Compliance Update

Cross-Border Compliance Update: December 2019

January 6, 2020

Foley Hoag’s Trade Sanctions & Export Controls Practice offers experienced, proactive regulatory advice to help clients avoid regulatory compliance missteps and to prevail in official proceedings. For more information about global compliance, visit the Foley Hoag Trade Sanctions & Export Controls Practice Group.

Included in this Issue:

  • DOJ Issues Revised Export Control and Sanctions Enforcement Policy for Business Organizations Providing Clear Guidance on the Benefits of Self-Disclosing Violations
  • The “New NAFTA:” Compliance Consequences of the United States-Mexico-Canada Agreement (USMCA)
  • Senator Menendez Blocks Transfer of Firearms Export Control from State Department to Commerce
  • Latest Iran Sanctions in Shipping and Aviation: Islamic Republic of Iran Shipping Lines (IRISL), E-Sail Shipping Company Ltd, and Mahan Air  
  • State Department Issues Advisory on the Export of Metals to Iran

ANTICORRUPTION SPOTLIGHT:

  • Happy (Belated) International Anticorruption Day!
  • OFAC Sanctions 68 Entities for Corruption and Human Rights Violations
  • Swedish Company Agrees to $1 Billion Settlement in Largest Foreign Corrupt Practices Act (FCPA) Enforcement Action
  • U.S. Trade Representative Proposes Duties on French Products in Response to France’s Digital Services Tax
  • South Sudan Officials Sanctioned for Undermining Peace Process; Visa Restrictions Announced
  • DOC Seeks Comments on Procedure for Entity List Entry Removal or Modification
  • Allianz Global Risks US Insurance Company Settles for Alleged Violations of the Cuban Assets Control Regulations (CACR)
  • OFAC Sanctions Guatemalan Mayor’s Drug Trafficking Organization

Excerpt:

DOJ Issues Revised Export Control and Sanctions Enforcement Policy for Business Organizations Providing Clear Guidance on the Benefits of Self-Disclosing Violations

On December 13, 2019, the Department of Justice (DOJ) released a new policy on voluntary self-disclosures of export control and sanctions violations (the “New VSD Policy”). In contrast to the guidance released in October 2016 regarding voluntary self-disclosures in export controls and sanctions investigations (the “2016 Guidance”), the New VSD Policy applies to all organizations, including financial institutions.

Download the December 2019 Foley Hoag Cross-Border Compliance Update (pdf).