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Court Opinion on Liability for Re-Exports to Iran Spurs Practical Guidance for U.S. Exporters

A recent federal appeals court decision addresses a familiar issue for many companies: When can a U.S. exporter be liable for a product that is re-exported to a sanctioned country, such as Iran? This update summarizes the...more

CFIUS: President-elect Trump’s Potential Big Stick for China and Foreign Trade

On the campaign trail, President-elect Trump adopted a contentious approach towards foreign trade, focusing on Chinese “theft of American trade secrets” and suggesting, at times, potential isolationism for U.S. businesses....more

United States Lifts Certain Sanctions Against Iran, With Limited Impact on U.S. Companies

The United States suspended certain “secondary sanctions” against Iran that apply to non-U.S. companies for transactions that take place outside of the United States and do not involve U.S. persons on “Implementation Day,”...more

New DoD Cybersecurity Rule and How Contractors Can Reduce Their Risks

The Department of Defense (DoD) issued an interim cybersecurity rule in August 2015 that, among other things, revises the existing Defense Federal Acquisition Regulation Supplement (DFARS) cybersecurity clause and increases...more

How U.S. Sanctions Can Affect Companies With Russian Investors

When the White House recently announced that it was extending sanctions against Russia for another year, it cited a continued “unusual and extraordinary threat” from Russia’s activities in Ukraine. President Obama also...more

Groundbreaking Change to Rules for Federal Contractors Aims to Stamp Out Human Trafficking Up and Down the Supply Chain

Companies that contract with the federal government will soon be subject to new rules aimed to stamp out human trafficking (see discussion of some of the existing rules and regulations here and here). The just-released...more

Russia, Venezuela and North Korea: U.S. Trade Sanctions Expand in International Markets

During the same week that President Barack Obama announced sweeping changes in the diplomatic and trade relationships between the United States and Cuba, the president signed congressional legislation authorizing additional...more

U.S. Embargo Against Cuba: Historic Changes Ahead

On December 17, 2014, President Barack Obama announced sweeping changes in the diplomatic and trade relationships between the United States and Cuba. These changes, outlined below, will require time to implement; certain...more

DoD's Updated FOIA Program and Exemption 4 Guidance

On September 3, 2014, the Department of Defense (DoD) issued a proposed rule updating its policies and procedures implementing the Freedom of Information Act (FOIA), including FOIA Exemption 4. FOIA Exemption 4 exempts from...more

Turmoil In Ukraine (Part II): U.S. Halts Export Licenses For Dual-Use And Defense Items To Russia; Congress Acts To Codify And...

U.S. government agencies announced this week that they have suspended issuing export licenses to companies sending or releasing sensitive goods, services and technology to Russia. This development will prevent companies from...more

3/31/2014  /  Exports , Foreign Policy , Russia , Sanctions , Ukraine

Turmoil In Ukraine: Actions Your Company Can Take Now As Sanctions Against Russia Escalate

Events are rapidly evolving with respect to Russia’s recent military incursion into, and subsequent annexation of, Ukraine’s Crimean Peninsula. The Obama Administration considers Russia’s acts to be clear violations of...more

3/24/2014  /  Foreign Policy , Russia , Sanctions , Ukraine

Protesting IDIQ Orders Under $10 Million? Here Are Your Options

Imagine that your company is a contract holder under a U.S. Army multiple award, indefinite-delivery, indefinite-quantity (IDIQ) contract. The Army issues a request for proposal for a firm, fixed-priced task order, and your...more

How Should U.S. Companies React To The Iran Nuclear Deal And Which Sanctions Are Suspended?

The United States agreed to suspend certain sanctions against Iran over the weekend as part of an agreement to curb the Iranian nuclear program. The agreement, which provides for a six-month first step towards a...more

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