International Regulation and Compliance

On May 15, 2025, the UK government published its first formal cross-government review of the implementation and enforcement of UK sanctions (the “Review”). The Review covers the period 2022-2023, evaluating how sanctions policy is delivered across the UK government and assessing the operational capability of relevant UK government departments and agencies. The Review also identifies a series of key findings that the UK government is committed to implementing during the next year, which offer a roadmap to some of the developments that will impact businesses’ sanctions compliance efforts over the coming months.   For more on the Review and its potential impact on the UK sanctions framework, read a new blog post by Alex Melia and Elliot Letts: https://lnkd.in/eP7P9pGN

On May 13, 2025, the Trump administration announced it would rescind and replace the Biden administration’s AI Diffusion Rule. In connection with its rescission of the Diffusion Rule, the Bureau of Industry and Security (BIS) issued three significant new guidance documents regarding AI-related national security risks, particularly with respect to Chinese technology firms. Steptoe's Export Controls and AI teams discuss the Trump administration's announcement and what may follow in a new blog post: https://lnkd.in/eu98YJxb

In this week's edition of the Sanctions Update, members of Steptoe's International Trade and Regulatory Compliance and Strategic Risk teams discuss President Trump's promise to lift sanctions on Syria, the UK's first cross-government review of sanctions implementation and enforcement, and the EU's 17th sanctions package against Russia, among other developments. Read the May 19, 2025 installment here: https://lnkd.in/eV9FJuJ5

On May 8, 2025, the U.S. Department of the Treasury announced plans to establish a "fast-track" pilot program for certain foreign investments subject to review by the Committee on Foreign Investment in the United States (CFIUS). This initiative, known as the "Known Investor" program, is intended to streamline the review process for foreign investors from allied and partner countries. The pilot furthers an initiative first announced in President Trump’s America First Investment Policy, which aims to encourage inbound investment flows from friendly countries while maintaining robust national security oversight for investment from higher risk jurisdictions. Steptoe's National Security and Cross-Border Transactions team covers the Known Investor pilot and its implications for foreign investors in a new blog post: https://lnkd.in/efJQwWYW

HM Treasury’s Office of Financial Sanctions Implementation (“OFSI”) has published a penalty notice concerning a £5,000 civil monetary penalty imposed on Svarog Shipping & Trading Company Limited (“Svarog”) on April 11, 2025, for failing to comply with an OFSI statutory request for information (“RFI”) within the specified time limit without a reasonable excuse under the UK’s Russia (Sanctions) (EU Exit) Regulations 2019 (the “Russia Regulations”). This marks the first time OFSI has issued a financial penalty solely for an information offence, and represents the second OFSI enforcement action in two months to target a failure to respond to an RFI issued by OFSI. Steptoe's Alex Melia and Elliot Letts explore the implications of OFSI's enforcement actions in a new blog post: https://lnkd.in/eXnA7Ckt

In this week's edition of the Sanctions Update, members of Steptoe's International Trade and Regulatory Compliance and Strategic Risk teams discuss new Burma-related sanctions, the UK's designation of Russian "shadow fleet" vessels, and the EU's 17th sanctions package against Russia, among other developments. Read the May 12, 2025 installment here: https://lnkd.in/eYwMnmd9

In this week's edition of the Sanctions Update, members of Steptoe's International Trade and Regulatory Compliance and Strategic Risk teams discuss the removal of Mike Waltz as National Security Adviser, the EU's recent Libya sanctions amendment, and China's decision to lift sanctions on members of the European Parliament, among other developments. Read the May 5, 2025 installment here: https://lnkd.in/eyA_9NDv

On April 30, 2025, the US Department of Justice’s (DOJ) National Security Division (NSD) announced a still-rare corporate declination under the NSD’s Export Control and Sanctions Enforcement Policy for Business Organizations (the “Policy”) in connection with a voluntary self-disclosure by Universities Space Research Association (USRA). This announcement – only the second publicly acknowledged declination since the Policy’s update in March 2024 – is significant insofar as it reflects a new ceiling for potentially criminal activity that, if quickly reported, may nevertheless warrant a declination under the Policy. It is also notable in that the current DOJ leadership is maintaining the Policy, at least for now, despite numerous material changes within NSD under the Trump administration.  Steptoe's Andrew Adams and Brian Fleming explore the NSD's recent declination and its implications in a new blog post: https://lnkd.in/eyfSEnTv

In this week's edition of the Sanctions Update, members of Steptoe's International Trade and Regulatory Compliance and Strategic Risk teams discuss the potential easing of US sanctions on Russia, the extension of EU sanctions on Myanmar, and China's designation of US officials, among other developments. Read the April 28, 2025 installment here: https://lnkd.in/eC_cfcqT

In this week's edition of the Sanctions Update, members of Steptoe's International Trade and Regulatory Compliance and Strategic Risk teams discuss new OFAC guidance on Iranian oil shipments, recent designations made by the UK and EU, and China's imposition of visa restrictions on US personnel, among other developments. Read the April 21, 2025 installment here: https://lnkd.in/ebPX3Q4C