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United States, European Union, United Kingdom, and Other Nations Impose Sanctions in Response to Russia’s Brutal Invasion of...

After less than a week of a full-scale war between Russia and Ukraine, the post-Cold War global architecture appears irrevocably shattered, as Western nations line up to offer support and military and economic aid to Ukraine...more

OFAC Year-in-Review 2021 Part II – Lessons Learned from OFAC’s 2021 Enforcement Actions

Back in July, we took a look at the enforcement actions for the first half of 2021 issued by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). Today’s post – the second half of our OFAC 2021 Year...more

OFAC Year in Review 2021 – Part 1

2021 was a year of transition in the United States and for the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). OFAC’s year, while busy, was far different from 2020, as the Biden Administration’s...more

Congress Pushes Legislation to Sanction Russia in Anticipation of Invasion of Ukraine

In response to Russia’s increasingly aggressive troop build-up on the Ukrainian border and the lack of progress of negotiations between Russia and the United States, Democrats and Republicans in Congress appear united in...more

National Defense Authorization Act – Implications for U.S. Sanctions Programs

In a closely followed and much anticipated action, President Biden signed the National Defense Authorization Act for Fiscal Year 2022 (NDAA) on December 27, 2021 – following its approval by the U.S. Senate and House of...more

Sanctions Legislation Watch: What to Expect from Congress as 2021 Comes to a Close

As we approach year’s end, and the pace of legislative activity ramps up, it remains critical to keep a close eye on the sanctions-related bills currently making their way, at varying speeds, through the U.S. legislative...more

BIS Releases Interim Final Rule on Export Controls for Cybersecurity Items

After several years of foreign and domestic negotiations surrounding controls on intrusion software, the U.S. Department of Commerce’s Bureau of Industry & Security (BIS) published an interim final rule on October 21, 2021,...more

No Surprises, But Fascinating Statistics on the Growth of Sanctions, as Treasury Releases its 2021 Sanctions Review

On October 18, 2021, the U.S. Department of the Treasury (“Treasury”) released its 2021 Sanctions Review (“Sanctions Review” or the “Review”), which includes recommendations for preserving the effectiveness of sanctions...more

Congress Re-Enters the Nord Stream 2 Fight with Amendment to NDAA

In the latest turn of events in the seemingly never-ending political saga of the Nord Stream 2 pipeline, the U.S. House of Representatives (the “House”), via an amendment to the 2022 National Defense Authorization Act...more

CFIUS Prepares To Block Semiconductor Sale To Chinese Entity

As close observers of the Committee on Foreign Investment in the United States (“CFIUS” or “Committee”) are aware, the Committee has the authority to recommend that the President of the United States block a transaction on...more

CFIUS By The Numbers: Key Takeaways From The 2020 Annual Report

On July 26, 2021, the Committee on Foreign Investment in the United States (CFIUS) released its unclassified Annual Report to Congress for the 2020 calendar year. The Annual Report provides statistics and insights into the...more

Lessons Learned From OFAC’s 2021 Enforcement Actions So Far

As peak summer holiday season approaches, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) continues to remind the private sector of the importance of strict economic sanctions compliance. OFAC...more

Biden Issues Executive Order To Reset And Expand Sanctions On Chinese Military And Surveillance Companies

On June 3, 2021, President Biden issued a new executive order (E.O.), “Addressing the Threat from Securities Investments that Finance Certain Companies of the People’s Republic of China” (E.O. 14032). The E.O. prohibits U.S....more

Senate Republicans Introduce Legislation To Impose Sanctions On Nord Stream 2 Following The Biden Administration’s Waiver

The legal and political skirmishing continued on both sides of the Atlantic in recent weeks over Nord Stream 2, the nearly finished Russian natural gas pipeline that continues to serve as a flash point within Europe and...more

Lessons Learned From OFAC’s 2020 Enforcement Actions

As we previously wrote in our OFAC 2020 Year in Review, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) saw a drop in enforcement activity in 2020, likely due to the massive year it had in 2019 and...more

OFAC 2020 Year In Review

In too many ways to count, 2020 was an extraordinary year. As we move into 2021 with optimism for an end to the pandemic and better days ahead, we understand that the activity last year of the U.S. Department of the...more

Biden Administration Issues Executive Order Re-Imposing Sanctions On Burma

On February 11, 2021, President Biden issued Executive Order 14014 of February 10, 2021, “Blocking Property With Respect to the Situation in Burma” (“E.O. 14014”), the first sanctions-related E.O. of his new administration,...more

Trump Administration Continues Its Aggressive Approach Toward Chinese Military Company Sanctions

Former US President Trump during his term of office only a week, before the release of its 13959 No. Executive Order ( "Executive Order") has been modified . The previous executive order prohibits Americans from investing in...more

Trump Administration Continues Its Aggressive Approach Toward Chinese Military Company Sanctions

With just one week remaining in his term, President Trump amended Executive Order (“EO”) 13959, which prohibits U.S. persons from investing in the securities of Chinese Military Companies (“CMCs”), to continue his aggressive...more

M&A In 2020 And Trends For 2021

2020 brought the COVID-19 pandemic and other headline-grabbing challenges, along with “the usual” quadrennial questions around the U.S. election. Early in the year, businesses and dealmakers focused on the pandemic and...more

New OFAC FAQs Clarifying And Broadening Sanctions On Chinese Military Companies

On December 28, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued five new frequently asked questions (“FAQs”) that clarify the scope of Executive Order (“E.O.”) 13959, the basis for OFAC’s...more

Defense Bill Aims Additional Sanctions At Turkey, Russia, And China

One of the widest-ranging bills of the U.S. Congress’s legislative year, the National Defense Authorization Act for Fiscal Year 2021 (NDAA), is nearing the finish line as both the House and Senate overwhelmingly approved the...more

Trump Administration Gives Teeth To Pentagon List And Restricts U.S. Investment In Publicly Traded Securities Of Chinese Military...

Over the past summer, prompted by a bipartisan Congressional letter identifying a two‑decade‑old statute as an unused tool in confronting China’s strategy of “Military-Civilian Fusion,” the U.S. Department of Defense (“DOD”)...more

OFAC Issues Advisory Highlighting Art Trade No “Goghs”

On October 30, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) published an advisory highlighting potential sanctions risks arising from dealings in “high-value artwork” (with “particular...more

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