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DoD's List of “Chinese Military Companies”: What's New and What It Means for You

The U.S. Department of Defense (“DoD”) updated its list of “Chinese military companies” operating “directly or indirectly” in the United States on January 31, 2024, adding 17 new entities and removing three. The list was...more

OFAC Interim Regulations Targeting Chinese Military Companies Have Limited Current Impact

On February 15, 2022, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) published an initial set of regulations to implement sanctions targeting investments in Chinese Military-Industrial Complex...more

OFAC Issues Guidance Indicating Aggressive Interpretation of China Military Company Sanctions

On December 28, 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) released guidance on the implementation of sanctions targeting securities of Communist Chinese military companies (“CCMCs”) imposed...more

Cloud Solutions Allowed for Encrypted, Unclassified Defense Data

The State Department’s Directorate of Defense Trade Controls (“DDTC”) published an interim final rule on December 26, 2019, bringing the International Traffic in Arms Regulations’ (“ITAR”) treatment of encrypted electronic...more

Financial Services Quarterly Report - Second Quarter 2018: Current U.S. Sanctions Against Russia, Venezuela and Iran

International sanctions are a major compliance challenge for companies worldwide. The regulatory risks associated with economic sanctions, asset-freezing measures and trade embargoes are not new, but they continue to grow in...more

New Law Significantly Expands Legal Basis for US Sanctions Against Russia

On 16 December 2014, President Obama announced that he will sign the Ukraine Freedom Support Act of 2014 (hereinafter the “Act”) into law. As discussed in our update dated 12 December 2014, the Act represents a potentially...more

US Clarifies Sanctions Provisions and US Senate Passes a Bill to Codify and Expand Sanctions

As noted in previous updates, the United States and European Union continue to impose sanctions against Ukrainian and Russian individuals and entities as a result of the turmoil in Ukraine. On 11 December 2014, the US Senate...more

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