We recently gathered a group of regulatory attorneys from across Reed Smith to provide a rundown of the key trends to watch for in Q2 2023. If you missed the webinar, you can access the recording on demand.
Please see a short summary of our top takeaways for Q2 below and look out for an invite to the next installment, where we will discuss the key trends for Q3. We hope you can join us!
Sanctions and export controls
- Sanctions and export control compliance should be top-of-mind for every business. The relevant agencies are putting the enforcement resources in place to drive this focus for years to come, beyond just issues with Russia, China, and Iran.
- It does not take much to establish a U.S. nexus sufficient to apply U.S. sanctions to foreign affiliates. Infrastructure in the U.S. used to support a transaction (e.g., servers, systems) or the use of U.S. dollars can be sufficient, even if no U.S. persons are involved.
- Sanctions screening expectations continue to evolve. Geolocation tools (i.e., IP blocking software) have become an essential element of a sanctions compliance program. Companies should also consider all known information about a customer or counterparty (e.g., information entered in free text boxes), not just standard screening fields like name and address.
U.S. Disruptive Technology Strike Force
- Justice and Commerce departments are leading an interagency strike force to investigate and prosecute illegal diversion of U.S. technologies to China, Iran, Russia, and North Korea.
- We anticipate an uptick in export control enforcement activity and increased private sector outreach by government investigators seeking to collect information regarding illicit procurement networks.
- Looking ahead, the U.S. government is exploring how to monitor outbound investments in dual-use technology to prevent providing adversaries with a national security advantage.