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In an age of fast-evolving geopolitical relations, security challenges and sanctions policies, the rules of international trade are affecting U.S. and multinational corporations, financial institutions, investors and even governments as never before. The Commerce Department's Bureau of Industry and Security (BIS), the State Department's Directorate of Defense Trade Controls (DDTC), and the Treasury Department's Office of Foreign Assets Control (OFAC), Financial Crimes Enforcement Network (FinCEN) and now the Committee on Foreign Investment in the United States (CFIUS) each plays an important role in administering and enforcing the intricate web of restrictions governing trade in U.S. products and technologies, the trade-related activities of U.S. parties and the financial transactions that make them possible.
Understanding the potential scope and applicability of these various regulatory programs to global business operations is increasingly important in an era of heightened agency enforcement and enhanced penalties. And a thorough understanding of these various regulatory regimes is an essential foundation for developing an effective global trade compliance program.
Aaron R. Hutman of Pillsbury Winthrop Shaw Pittman LLP and Joshua N. Williams of Covington & Burling LLP will discuss:
• The basic elements of the export control regimes administered by BIS and DDTC
• The various economic sanctions programs administered by OFAC
• The overlap of sanctions and export control rules with anti-money laundering regulation and the role of financial institution “gatekeepers”
• The new role of CFIUS under its recently-announced Pilot Program
• Enforcement trends
This Briefing is scheduled as a review of the fundamentals before PLI’s more advanced Coping with U.S. Export Controls and Sanctions 2019 program, being held on December 12-13, 2019 in Washington, D.C. Please register for the two-day program and receive this Briefing free as part of your registration.
Program Level: Basic
Intended Audience: Law firm attorneys, in-house counsel, compliance managers, banking industry participants, ACAMS, international trade industry professionals, private equity and hedge fund managers, accounting professionals and policy experts inside or outside of government
Advanced Preparation: None