Although most joint ventures have long (if not indefinite) terms, in turbulent economic times, corporate joint venture partners are more likely to reconsider their commercial arrangements. And in some cases, parties may...more
On October 15, 2021, the US Department of the Treasury’s Office of Foreign Assets Control ("OFAC") issued a brochure to promote sanctions compliance in the virtual currency industry (the "Guidance")1 and updated two related...more
On March 25, 2021, the United States imposed sanctions on Myanma Economic Holdings Public Company Limited ("MEHL") and Myanmar Economic Corporation Limited ("MEC"), Burma's two largest military conglomerates. On the same day,...more
On February 1, 2021, the Burmese military announced that it had seized control of the country from the country's democratically elected government.1 In response to the coup, the US has so far designated 12 individuals and...more
3/11/2021
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Burma ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Myanmar ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Sanctions ,
SDN List
On 2 March 2021, the United States and European Union ("EU") imposed coordinated sanctions in response to the poisoning and imprisonment of Russian opposition politician Aleksey Navalny (and the related US determination that...more
On December 23, 2020, the US Department of Commerce's Bureau of Industry and Security ("BIS") issued a final rule creating a "Military End User List" ("MEU List") under the Export Administration Regulations ("EAR"). The final...more
1/8/2021
/ Bureau of Industry and Security (BIS) ,
China ,
Exceptions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Final Rules ,
General Licenses ,
Licensing Rules ,
Military End Use ,
National Security ,
U.S. Commerce Department
On October 1, 2020, the US Department of the Treasury's Office of Foreign Assets Control ("OFAC") issued an advisory opinion on the sanctions risks associated with certain cyberattacks ("OFAC Guidance"). The OFAC Guidance...more
10/12/2020
/ Compliance ,
Cyber Attacks ,
Cybersecurity ,
Economic Sanctions ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
Ransomware ,
Risk Assessment ,
Risk Management ,
Sanction Violations ,
SDN List ,
U.S. Treasury
On August 17, 2020, the US Commerce Department's Bureau of Industry and Security (BIS) issued two final rules that expand the scope of licensing requirements for transactions involving parties on the Entity List. Both rules...more
8/30/2020
/ Bureau of Industry and Security (BIS) ,
China ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Foreign-Produced Direct Product Rule (DPR) ,
General Licenses ,
Huawei ,
Licensing Rules ,
New Rules ,
Popular ,
Savings Clause ,
Scope of Coverage ,
Shipping ,
Technology Sector
On April 28, 2020, the US Commerce Department's Bureau of Industry and Security (BIS) published two new final rules amending the Export Administration Regulations (EAR). One of the final rules removes license exception Civil...more
5/6/2020
/ Bureau of Industry and Security (BIS) ,
China ,
Commerce Control List ,
Economic Sanctions ,
Electronic Export Information (EEI) ,
End-Users ,
Exceptions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Licensing Rules ,
Military End Use ,
Russia ,
U.S. Commerce Department ,
Venezuela
On January 6, 2020, the US Department of Commerce's Bureau of Industry and Security (BIS) issued the first "emerging technology" rule to control artificial intelligence-based software specially designed to automate the...more
2/10/2020
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Artificial Intelligence ,
Bureau of Industry and Security (BIS) ,
CFIUS ,
Classification ,
ECCNs ,
Emerging Technologies ,
Export Control Reform Act (ECRA) ,
Exports ,
FIRRMA ,
Imports ,
Interim Final Rules (IFR) ,
Public Comment ,
Software ,
Software Licenses ,
Technology Sector ,
U.S. Commerce Department
On January 10, 2020, the President signed a new Executive Order (EO), "Imposing Sanctions With Respect to Additional Sectors of Iran," targeting Iran's construction, mining, manufacturing, and textiles industries. On the same...more
1/15/2020
/ Aluminum Sales ,
Blocked Person ,
Construction Industry ,
Economic Sanctions ,
Executive Orders ,
Foreign Financial Institutions (FFI) ,
Iran ,
Iran Sanctions ,
Manufacturers ,
Metals ,
Mining ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Steel Industry ,
Textiles ,
Trump Administration
On November 27, 2019, the US Department of Commerce (Commerce) issued a notice of proposed rulemaking on the implementation of Executive Order 13873 (the EO), "Securing the Information and Communications Technology and...more
12/3/2019
/ Executive Orders ,
Foreign Adversaries ,
Information and Communication Technology (ICT) ,
Jurisdiction ,
National Security ,
Notice of Proposed Rulemaking (NOPR) ,
Prohibited Transactions ,
Public Comment ,
Secretary of Commerce ,
Technology Sector ,
Telecommunications ,
Trump Administration ,
U.S. Commerce Department
On August 2, 2019, the United States announced the imposition of additional sanctions on the Russian Federation under the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (CBW Act)....more
8/8/2019
/ Banks ,
Biological-Weapons ,
Bonds ,
Bureau of Industry and Security (BIS) ,
Chemical Warfare ,
Chemical Weapons ,
Economic Sanctions ,
Export Controls ,
Exports ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Trump Administration
On June 30, 2019, China's National Development & Reform Commission (NDRC) and the Ministry of Commerce (MOFCOM) jointly issued the updated negative lists for year 2019 (the 2019 Negative Lists) that set out the sectors where...more
The US Commerce Department’s Bureau of Industry and Security (BIS) added Huawei Technologies Co., Ltd. (Huawei) and 68 non-US Huawei affiliates to the BIS Entity List, effective May 16, 2019, at 4:15 p.m. Eastern Daylight...more
5/28/2019
/ Bureau of Industry and Security (BIS) ,
Cybersecurity ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
General Licenses ,
Huawei ,
Network Security ,
Networks ,
Technology Sector ,
Telecommunications ,
U.S. Commerce Department
On May 15, 2019, President Trump issued an executive order (EO), "Executive Order on Securing the Information and Communications Technology and Services Supply Chain," prohibiting certain transactions involving...more
5/21/2019
/ Bureau of Industry and Security (BIS) ,
CFIUS ,
China ,
Cybersecurity ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Executive Orders ,
Export Controls ,
FIRRMA ,
Foreign Acquisitions ,
Foreign Adversaries ,
Hackers ,
Indictments ,
Industrial Espionage ,
Information Technology ,
Intellectual Property Protection ,
National Security ,
Popular ,
Prohibited Transactions ,
Proposed Legislation ,
Supply Chain ,
Telecommunications ,
Trade Secrets ,
Transfer Restrictions ,
Trump Administration ,
U.S. Commerce Department
On May 8, 2019, following Iran's announcement that it intends to suspend certain nuclear proliferation-related commitments under the Joint Comprehensive Plan of Action (JCPOA), the United States issued a new Executive order...more
5/14/2019
/ Blocking Sanctions ,
Blocking Statutes ,
CAPTA List ,
China ,
Economic Sanctions ,
EU ,
Executive Orders ,
Foreign Financial Institutions (FFI) ,
France ,
Germany ,
IFCA ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Metals ,
Nuclear Power ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Prohibited Transactions ,
SDN List ,
Steel Industry ,
Suspensions ,
Trump Administration ,
UK ,
Waivers
On May 2, 2019, claimants began filing lawsuits for the first time under Title III of the Helms-Burton Act against third parties alleged to be "trafficking" in property of US nationals confiscated by the Cuban Government...more
5/9/2019
/ Blocking Statutes ,
Canada ,
Confiscated Property ,
Cuba ,
EU ,
FSCS ,
Helms-Burton Act ,
Orders of Prohibition ,
Personal Remittance Caps ,
Sanction Suspensions ,
Statute of Limitations ,
Third-Party ,
Title III ,
Trafficking ,
Travel Restrictions ,
Trump Administration ,
UK ,
US Department of State
On 31 January 2019, France, Germany and the United Kingdom (the "E3") announced the registration in France of INSTEX SAS ("Instrument for Supporting Trade Exchanges"), which is a special purpose vehicle aimed at facilitating...more
2/14/2019
/ AML/CFT ,
Blocking Statutes ,
EU ,
FATF ,
France ,
Germany ,
INSTEX ,
International Atomic Energy Agency ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Special Purpose Vehicles ,
UK ,
United Nations
On January 28, 2019, the Department of the Treasury's Office of Foreign Assets Control (OFAC) designated Petróleos de Venezuela, S.A. (PdVSA) on the List of Specially Designated Nationals and Blocked Persons (SDN List). PdVSA...more
2/11/2019
/ Banking Sector ,
Blocked Person ,
Coercion ,
Dispute Resolution ,
Economic Sanctions ,
Executive Orders ,
Financial Institutions ,
Foreign Policy ,
GATT ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Petroleum ,
SDN List ,
Trade Restrictions ,
Trump Administration ,
Venezuela ,
WTO
On January 27, 2019, the US Department of the Treasury's Office of Foreign Assets Control (OFAC) lifted sanctions imposed on En+ Group plc (En+), UC Rusal plc (Rusal), and JSC EuroSibEnergo (ESE), removing these entities from...more
On 21 January 2019, the EU adopted the first sanctions measures under its new sanctions framework targeting parties involved in the use and proliferation of chemical weapons introduced in October 2018...more