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One Step Forward, Two Steps Back: The New Proposed Rule For Export, Reexport & Transfers To The People’s Republic Of China
In 2005, United States companies exported approximately $41 billion worth of items to the People’s Republic of China. During that same time period, American business concerns reportedly lost an estimated $12.5 billion in potential export revenue.
United States
15 Sep 2006
Big Money for BIS: A Fivefold Increase in Maximum Penalties Under the IEEPA
As part of the USA PATRIOT Improvement and Reauthorization Act signed by the President on March 9, 2006, lawmakers added a small piece of legislation entitled the Combating Terrorism Financing Act of 2005 (Title IV) ("the Act"). One of the primary purposes of this Act is to raise the maximum amount for civil penalties under the International Emergency Economic Powers Act from $10,000 per violation (adjusted to $11,000 per violation under the Federal Civil Penalties Adjustment Act of 1990) to $50
United States
16 Jun 2006
OFAC Reissues Burma Sanctions Regulations
The Office of Foreign Assets Control ("OFAC") issued an interim final rule on August 16, 2005, revising the Burmese Sanctions Regulations (the "Regulations"). While Burma has been subject to sanctions since 1997, the passage of the Burmese Freedom and Democracy Act of 2003 (the "Act"), plus President Bush’s Executive Order of July 28, 2003, led to extensive revisions of the Burmese sanctions program. As a result of these amendments, OFAC decided to reissue the Regulations in their entirety.
United States
30 Nov 2005
Lose Your Clearance, Lose Your Contract, Lose Your Company
One of the most valuable commodities held by a federal government contractor is its employees holding active personnel security clearances. Greater contracting opportunities across the federal government have only served to increase the value of these cleared employees by keeping companies competitive for government projects where access to classified information is necessary to perform tasks or services essential to the fulfillment of the contract. In many cases, the inability of specific contr
United States
23 Mar 2005
FinCEN Issues New Guidance on Anti-Money Laundering Program Requirements for Foreign Agents and Foreign Counterparts
On December 8, 2004, the U.S. Department of the Treasury Financial Crimes Enforcement Network ("FinCEN") issued interpretive Guidance requiring Money Services Businesses that use overseas agents to move funds in and out of the United States to establish, as part of their anti-money laundering procedures, appropriate measures to address the risks of money laundering and terrorism financing posed by relationships with foreign parties. Businesses are expected to be fully compliant with this Guidanc
United States
11 Mar 2005
Exporting Without Importing a Headache: An Application of the U.S. Export Regulations to The Financial Services Industry
Just as it is essential for financial services institutions and other business entities to have internal systems in place to meet their employment law and tax obligations, they also must implement comprehensive programs to ensure compliance with United States export, anti-boycott, anti-money laundering, and sanctions laws. These complex international regulatory schemes demand that companies have a thorough understanding of these requirements so that no transaction is conducted contrary to these
United States
9 Feb 2005
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