Effective April 24, the statute of limitations (“SoL”) under the International Emergency Economic Powers Act (“IEEPA”) and the Trading with the Enemy Act (“TWEA”) has been extended from five to ten years. It would have been easy to miss this change, buried within a supplemental emergency appropriation bill (H.R. 815) signed into law by President Biden on April 24, 2024, but its impacts will be profound for entities facing internal or government investigations for sanctions violations.Continue Reading Say SoL Long to Short Limits: Doubling Down on the Sanctions Statute of Limitations
Reid Whitten
Reid is the Managing Partner of Sheppard Mullin's London office, practicing in international trade regulations and investigations.
Does Your Trade Policy Support Your Company’s Values?
If your company is like many, your board of directors may be demanding that you put more effort into environmental, social, and governance issues, which have become known by the now-ubiquitous acronym “ESG.” Those demands don’t come from nowhere: consumers are demanding transparency and social responsibility. In addition, if your company does business internationally, regulators are now focused on international social justice issues (such as the use of forced labor) more than ever.
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The Next Four Years in International Business
Over the past few weeks, we have been speculating on the international trends and tides we expect to see in the next four years under a new U.S. presidential administration. So that you can enjoy our prognostications (before our program gets greenlighted as a Netflix special) we provide here:
- A recording of our webinar, entitled “The Four Years in International Business Webinar”
(for those playing along at home, see if you can spot the part where Scott’s power goes out while we’re discussing tariff reductions!)
- A bulleted summary of the key takeaways of our webinar.
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Export Control HR Pitfalls To Avoid When Hiring
Hiring employees does not usually call to mind international trade compliance obligations. However, together U.S. export controls and anti-discrimination laws create a web that is overlooked or misunderstood by many types of employers of all sizes across many industries. Anti-discrimination laws prohibit unlawful citizenship status restrictions when hiring, and U.S. export controls prohibit disclosing controlled information to foreign nationals without authorization. Together, these laws limit acceptable job descriptions and hiring practices.
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A New Latitude: Charting a Course for Cuba
Today President Barack Obama made a stunning speech announcing steps the United States will take to reduce U.S. sanctions against Cuba. The announcement followed the release of two U.S. citizens held by the Cuban government. Alan Gross was detained by Cuban authorities in 2009 while working as a USAID subcontractor. Separately, a U.S. intelligence officer, not named in the announcement but described by the President as “one of the most important” U.S. intelligence agents in Cuba, had been imprisoned in Cuba for nearly two decades.
Continue Reading A New Latitude: Charting a Course for Cuba