Ed Krauland

Ed Krauland

Edward J. Krauland focuses on export controls/economic sanctions.  Mr. Krauland’s extensive experience includes representing clients on matters involving US and multilateral economic sanctions, defense and nuclear export controls, dual-use export controls under the EAR, anti-boycott compliance, internal investigations and enforcement work, and review of government procurement regulations in the cross-border context.  His practice spans all aspects of these laws, including counseling, compliance work, transactional advice, licensing and opinion work, internal reviews, disclosures, and enforcement actions.  He has served as co-chair of the International Trade Committee of the ABA Section of International Law and Practice.  He is former Chairman of an ABA-wide Task Force on Gatekeeper Regulation (anti-money laundering compliance), and senior adviser to the ABA Section of International Law and Practice’s anti-money laundering committee.

Read Mr. Krauland’s full bio.

Subscribe to all posts by Ed Krauland

Trump Designates North Korea as a ‘State Sponsor of Terrorism,’ Makes Additional Sanctions Designations

On November 20, 2017, President Trump announced that North Korea would be designated a “state sponsor of terrorism.”  The only other countries with this designation are Syria, Iran, and Sudan.  The president also stated that the United States would announce the imposition of additional sanctions on Pyongyang.  The next day, the US Department of the … Continue Reading

WorldECR Publishes Article on EAR License Exceptions

Steptoe’s Ed Krauland and Anthony Rapa authored an article on Export Administration Regulations (EAR) license exceptions published in WorldECR’s July 2017 issue. The article discusses the pros and cons of license exceptions, which can offer exporters a host of cost, time, and efficiency benefits. They argue that, when mastered, these license exceptions can be a … Continue Reading

OFAC Penalizes AIG’s Voluntary Disclosure of Overly “Narrow” Exclusion Clauses and Single Shipment Policies

On June 26, 2017, American International Group, Inc. (AIG) agreed to a $148,698 civil settlement with OFAC based on a voluntary disclosure of 555 apparent violations of OFAC’s Iran, Sudan, Cuba and Weapons of Mass Destruction Proliferators economic sanctions programs.  AIG processed approximately $396,530 in premiums and paid claims on policies covering maritime shipments of … Continue Reading

OFAC Takes Sanctions Jurisdiction Into Uncharted Waters

On February 3, 2017, the US Treasury Department’s Office of Foreign Assets Control issued a finding of violation against Taiwan-based B Whale Corp. (BWC), a member of the Taiwan-based shipping company TMT Group. The finding of violation was issued for activity occurring entirely outside the United States, based on the jurisdictional finding that “BWC was … Continue Reading

Groundbreaking Russia Sanctions Bill Introduced in the Senate

A bipartisan group of US Senators introduced a bill on January 11, 2017 – the Countering Russian Hostilities Act of 2017 – that would impose unprecedented sanctions on Russia and persons and entities conducting certain types of business involving Russia.  This bill would codify into law most of the existing sanctions targeting Russia, making it … Continue Reading

DDTC and BIS Publish Long-Awaited Final Rules for Category XII: Night Vision and Cameras

On October 12, 2016, the State Department’s Directorate of Defense Trade Controls (DDTC) and the Commerce Department’s Bureau of Industry and Security (BIS) published companion final rules to amend Category XII of the United States Munitions List (USML) and move some less sensitive items to the Commerce Control List (CCL).  The final rules will become … Continue Reading

Roundup of Recent AML/Sanctions Enforcement Actions

Capping off a year of robust sanctions enforcement, two recent enforcement actions highlight the risks of doing business with sanctioned countries, in particular Iran.  In December 2016, federal and New York state regulators initiated enforcement actions related to alleged sanctions violations involving Iran.  In the first enforcement action, Italy’s largest retail bank, Intesa Sanpaolo SpA … Continue Reading

UK Government Seek Consultations on New Civil Penalties For Violations of Economic Sanctions

The UK’s HM Treasury is holding a consultation, which is open for comment through January 26, 2017, on the process for the imposition of civil penalties for breaching financial sanctions.  This is a major departure from the current law, which has not produced many enforcement actions, as it currently only allows for criminal enforcement of sanctions … Continue Reading

UN Tightens the Screws on North Korea with Additional Trade and Banking Sanctions

On November 30, 2016, UN Security Council Resolution (UNSCR) 2321 was adopted, pushing the limits on how far international economic sanctions can go in isolating the North Korean regime without entirely collapsing the country’s economy.  The resolution also lays out a handful of additional legal restrictions that will be pertinent for US and international stakeholders … Continue Reading

Customer Due Diligence Guidance by FinCEN for Certain Financial Institutions

On July 19, 2016, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued Frequently Asked Questions to clarify the scope of its rule, “Customer Due Diligence (CDD) Requirements for Financial Institutions.”  Steptoe’s International Compliance Blog covered the rule in May. This rule took effect on July 11, 2016, but does not require … Continue Reading
LexBlog