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Trump 2.0: U.S. Imposes Tariffs on Key Trading Partners 

After months of anticipation, on February 1, 2025, President Trump announced the imposition of significant tariffs on Mexico, Canada, and China through three Executive Orders (EOs). While additional details are expected to be...more

BIS Issues Interim Final Rule Establishing a Framework for Artificial Intelligence Diffusion

On January 13, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued an Interim Final Rule (IFR), establishing new export controls targeting advanced artificial intelligence (AI) chips and model...more

Framework for Collaboration Between U.S. and UK Sanctions Authorities

Earlier this week, the U.S. Office of Foreign Assets Control (OFAC) and the UK Office of Financial Sanctions Implementation (OFSI) published a Memorandum of Understanding (MoU), which was previously signed on October 9, 2024,...more

U.S. Increases Export Restrictions Against Nicaragua

The U.S. Department of Commerce amended the Export Administration Regulations (EAR), effective March 15, 2024, to move Nicaragua from Country Group B to Country Group D, and added it to the list of countries subject to the...more

Voluntary Self-Disclosure: Is the Value Self-Evident?

How should companies think about DOJ, BIS and OFAC voluntary disclosure in the wake of the DOJ’s massive investment in sanctions and export control enforcement? The DOJ, BIS and OFAC released a joint compliance note...more

Commerce Releases New Proposed Rule Governing Restrictions on Chinese Investments by CHIPS Act Applicants

The proposed rule tightens restrictions on activities by “affiliates” and clarifies scope of statutory clawbacks. The Department of Commerce released a proposed rule imposing guardrails preventing the “improper use of...more

Saudi Arabia Launches New Committee to Examine Foreign Investments

On September 14, 2021, the Kingdom of Saudi Arabia’s (KSA’ s) Cabinet of Ministers launched a new Permanent Ministerial Committee for Examining Foreign Investments (CEFI) that would review foreign investments for potential...more

Biden Administration Updates Framework for China-Related Investment Prohibitions and Expands the Scope of Restricted Chinese...

E.O. 14032 signals that the Biden Administration will continue to restrict U.S. investments into China’s defense and surveillance technology sectors. The prior Administration’s November 2020 Executive Order (E.O.) 13959...more

Commerce Department’s New ICTS Rule Raises Additional Considerations for Cross-Border Transactions

On January 19, 2021, the Commerce Department issued an interim final rule to implement the Executive Order on Securing the Information and Communications Technology and Services Supply Chain (E.O. 13873), which was issued on...more

Supply Chain Threats and Cybersecurity Compliance Issues on the Horizon

New rules and developments continue to proliferate as the U.S. government seeks to minimize supply chain threats and cybersecurity risks. For contract awards issued after August 13, 2020, prime contractors must conduct a...more

New Proposed CFIUS Regulations Implementing FIRRMA

On September 17, 2019, the U.S. Department of Treasury issued two new proposed rules for the Committee on Foreign Investment in the United States (CFIUS) implementing the Foreign Investment Risk Review Modernization Act...more

Huawei Remains on the BIS Entity List but Senior Officials Suggest Export Licenses May Be Considered

As trade relations with China continue to evolve, Huawei Technologies Co., Ltd. (“Huawei”) and its foreign affiliates remain subject to broad U.S. export license requirements. ...more

U.S. Commerce Department Releases Proposed Rulemaking for Export Controls on Emerging Technologies

On November 19, 2018, the US Commerce Department’s Bureau of Industry and Security (BIS) issued a proposed rulemaking seeking public comment on criteria for identifying emerging technologies that are essential to U.S....more

State Department Imposes Chemical Weapons Sanctions on Russia

On August 8, 2018, the State Department announced that it had concluded that Russia was responsible for poisoning former double agent Sergei Skripal and his daughter Yulia using the nerve agent Novichok and that it had sent a...more

New Executive Order Allows for Sanctions Related to Cybersecurity

On April 1, 2015, President Obama issued a groundbreaking Executive Order (E.O.) enabling the United States to sanction persons that have (1) participated in malicious cyber-enabled activities constituting a “significant...more

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