On the eve of the 2024 Group of Seven (G7) Leaders’ Summit, the United States imposed new sanctions and export control measures against Russia further targeting sanctions evaders and, for the first time, the Russian...more
6/19/2024
/ Asset Seizure ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
EU ,
Export Administration Regulations (EAR) ,
Export Controls ,
Financial Services Industry ,
Foreign Financial Institutions (FFI) ,
Information Technology ,
Infrastructure ,
International Securities Market (ISM) ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
SDN List ,
Software ,
UK
On the second anniversary of the start of the war in Ukraine and in response to the death of activist Aleksey Navalny in a Russian prison, the United States, European Union, and United Kingdom, along with Australia and...more
3/4/2024
/ Asset Freeze ,
Australia ,
Bureau of Industry and Security (BIS) ,
Canada ,
China ,
Economic Sanctions ,
Energy Sector ,
EU ,
Export Controls ,
Financial Services Industry ,
India ,
Mining ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Transportation Industry ,
Turkey ,
UK ,
Ukraine ,
United Arab Emirates (UAE) ,
US State Departments
On September 25, 2023, the U.S. Department of Commerce (“Commerce”) issued the final rule (the “Final Rule”) regarding the use of funds offered under the CHIPS and Science Act (the “CHIPS Act”).
The Final Rule...more
10/11/2023
/ Clawbacks ,
Export Administration Regulations (EAR) ,
Export Controls ,
Final Rules ,
Importers ,
National Security ,
NIST ,
Risk Management ,
Risk Mitigation ,
Semiconductors ,
U.S. Commerce Department
On April 18, 2023, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) Assistant Secretary for Export Enforcement, Matthew Axelrod, published a memorandum marking a shift in policy regarding voluntary...more
Since February 2022, the United States, United Kingdom, and European Union have imposed unprecedented economic sanctions on Russia and various Russian entities and individuals in response to the war in Ukraine.
Actions have...more
12/19/2022
/ Asset Freeze ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement ,
EU ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Investment ,
Good Faith ,
Imports ,
Maritime Transport ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Popular ,
Russia ,
Safe Harbors ,
SDN List ,
U.S. Treasury ,
UK ,
Ukraine
Background As noted in our prior update, the United States, European Union and United Kingdom imposed a number of sanctions in connection with Russia’s recognition of the Donetsk and Luhansk regions of Ukraine. ...more
2/28/2022
/ Asset Freeze ,
Biden Administration ,
Economic Sanctions ,
EU ,
Export Controls ,
Financial Transactions ,
Foreign Policy ,
Foreign Relations ,
Foreign Trade Regulations ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
UK ,
Ukraine ,
Vladimir Putin
Russia's Actions -
On February 21, 2022, Russian President Vladimir Putin signed two executive orders recognizing the DNR/LNR Regions as “sovereign and independent states.”...more
2/23/2022
/ Biden Administration ,
Blocked Person ,
Critical Infrastructure Sectors ,
Economic Sanctions ,
Enforcement Priorities ,
Export Controls ,
Financial Transactions ,
Foreign Policy ,
Foreign Relations ,
Foreign Trade Regulations ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Ukraine ,
Vladimir Putin
The U.S.-China trade war continues to escalate, most recently fueled by U.S. concerns over China’s assertion of increasing authority over Hong Kong. The U.S. and Chinese governments have exchanged jabs through the use of...more
7/17/2020
/ CFIUS ,
China ,
Criminal Prosecution ,
Economic Sanctions ,
Exceptions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Free Speech ,
Free Trade Agreements ,
Freedom of the Press ,
Hong Kong ,
Hong Kong Autonomy Act (HKAA) ,
Human Rights ,
Open General Export Licences (OGELs) ,
Popular ,
Revocation ,
Right to Peaceful Assembly ,
SDN List ,
Section 301 ,
Tariffs ,
Technology Sector ,
Trade Act of 1974 ,
Trade Policy ,
Trade Wars ,
Travel Ban ,
Trump Administration ,
United States
The U.S. Department of the Treasury (“Treasury”) published two sets of interim rules on October 10, 2018, implementing certain provisions of the Foreign Investment Risk Review Modernization Act (“FIRRMA”). In addition to...more
10/16/2018
/ Bureau of Industry and Security (BIS) ,
CFIUS ,
Critical Infrastructure Sectors ,
Export Administration Regulations (EAR) ,
Export Controls ,
Federal Pilot Programs ,
FIRRMA ,
Foreign Acquisitions ,
Foreign Investment ,
Interim Rule ,
ITAR ,
Mandatory Declarations ,
National Security ,
Non-Controlling Interests ,
Petrochemicals ,
Technology Sector ,
Trump Administration
After conferees from the U.S. House of Representatives (House) and U.S. Senate (Senate) reached agreement on the Foreign Investment Risk Review Modernization Act (FIRRMA), the House on Thursday, June 26, 2018, passed...more
8/1/2018
/ CFIUS ,
Critical Infrastructure Sectors ,
Export Controls ,
FIRRMA ,
Foreign Acquisitions ,
Foreign Investment ,
Investment Funds ,
Mergers ,
National Security ,
National Security Review Proceedings ,
Private Equity ,
Real Estate Investments ,
Trump Administration
The U.S. House of Representatives (the House) on June 26, 2018, passed legislation designed to reform and strengthen the authority of the Committee on Foreign Investment in the United States (CFIUS or the Committee), the...more
6/28/2018
/ Acquisitions ,
CFIUS ,
Cross-Border Transactions ,
Export Controls ,
FIRRMA ,
Foreign Acquisitions ,
Foreign Investment ,
Manufacturers ,
National Security ,
Proposed Legislation ,
Trump Administration
While the rules regarding CFIUS review have remained largely unchanged over the past decade, CFIUS has operated under a new paradigm in recent years. After the U.S. government blocked just two transactions from its inception...more
6/21/2018
/ CFIUS ,
China ,
Corporate Counsel ,
Covered Transactions ,
Critical Infrastructure Sectors ,
Disparate Treatment ,
Export Controls ,
FIRRMA ,
Foreign Acquisitions ,
Foreign Direct Investment ,
Foreign Investment ,
Intellectual Property Protection ,
National Security ,
NDAA ,
Passive Investments ,
Pending Legislation ,
Real Estate Investments ,
Rollbacks ,
Sanctions ,
Telecommunications ,
Transfer of Control ,
Trump Administration ,
U.S. Commerce Department ,
ZTE
The U.S. Government this week announced changes to U.S. sanctions against Cuba to implement various policy changes announced by President Trump in July 2017 (for additional background, see our prior OnPoint from June 2017)....more
11/10/2017
/ Cuba ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Financial Transactions ,
Foreign Policy ,
Government Officials ,
International Travel ,
Open General Export Licences (OGELs) ,
Travel Restrictions ,
Trump Administration
The U.S. Commerce and Treasury Departments announced on January 26, 2016, actions to ease certain restrictions on transactions involving Cuba. The new actions do not significantly expand the types of activities in which U.S....more
U.S. Commerce and Treasury Department measures intended to further ease existing export and sanctions restrictions regarding Cuba took effect on September 21, 2015. These amendments to the Cuban Assets Control Regulations...more