On 5 January 2021, President Donald Trump issued Executive Order (EO) 13971 on "Addressing the Threat Posed By Applications and Other Software Developed or Controlled By Chinese Companies," which prohibits U.S. persons from...more
Recent court rulings enjoining enforcement of the Trump Administration’s Executive Order (“EO”) targeting TikTok show signs of curbing the sweeping powers of the International Emergency Economic Powers Act (“IEEPA”), which...more
On 14 July, the same day the president signed into law the Hong Kong Autonomy Act (the act), President Trump issued the Executive Order on Hong Kong Normalization (the EO) directing federal agencies to impose a range of trade...more
On 27 May 2020 U.S. Secretary of State Pompeo certified to Congress that the State Department no longer considers Hong Kong to have significant autonomy from China and therefore "Hong Kong does not continue to warrant...more
On 1 May 2020 President Trump issued an "Executive Order on Securing the United States Bulk-Power System" (the Bulk-Power System EO), which establishes a framework for imposing broad new restrictions on the acquisition,...more
On 10 January 2020, in response to missile attacks by the Iranian military targeting two U.S. bases in Iraq, the United States Department of the Treasury, Office of Foreign Assets Control (OFAC) designated a number of senior...more
1/14/2020
/ Blocked Person ,
Construction Project ,
Economic Sanctions ,
Executive Orders ,
Foreign Policy ,
Foreign Relations ,
Goods or Services ,
Iran ,
Iran Sanctions ,
Manufacturers ,
Mining ,
Office of Foreign Assets Control (OFAC) ,
Prohibited Transactions ,
SDN List ,
Textiles ,
Trump Administration
On 26 November 2019 the U.S. Department of Commerce issued a long-awaited proposed rule (or draft regulations) to implement Executive Order 13873, "Securing the Information and Communications Technology and Services Supply...more
11/27/2019
/ Acquisitions ,
Critical Infrastructure Sectors ,
Foreign Adversaries ,
Imports ,
Proposed Rules ,
Risk Assessment ,
Risk Management ,
Secretary of Commerce ,
Supply Chain ,
Telecommunications ,
Trump Administration ,
U.S. Commerce Department
On 25 October the U.S. Departments of the Treasury and State announced the establishment of a new channel for conducting due diligence on humanitarian trade with Iran.
Foreign governments and foreign financial institutions...more
11/8/2019
/ AML/CFT ,
Due Diligence ,
FinCEN ,
Foreign Financial Institutions (FFI) ,
Foreign Relations ,
Humanitarian Assistance ,
Iran ,
Iran Sanctions ,
Money Laundering ,
Office of Foreign Assets Control (OFAC) ,
Reporting Requirements ,
Trump Administration
Recent actions by the U.S. Department of State underscore the Trump administration's efforts to use a "whole of government" approach to address perceived national security threats posed by China.
While these actions do not...more
On 4 September 2019 the U.S. State Department issued "Draft 'U.S. Government Guidance for the Export of Hardware, Software and Technology with Surveillance Capabilities and/or parts/know-how'" (draft guidance).
...more
9/12/2019
/ Artificial Intelligence ,
Best Practices ,
Big Data ,
Comment Period ,
Compliance Management Systems ,
Draft Guidance ,
Drones ,
Due Diligence ,
Economic Sanctions ,
Export Controls ,
Exports ,
Facial Recognition Technology ,
Human Rights ,
Policies and Procedures ,
Social Media ,
Software Developers ,
Spyware ,
Surveillance ,
Telecommunications ,
Trump Administration ,
US State Departments
On 2 August the United States announced that it will impose a second round of sanctions on Russia pursuant to the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (CBW Act) (22 U.S.C. § 5601 et...more
On 5 August 2019 the Trump administration issued Executive Order 13884 (the executive order) imposing sweeping sanctions against the government of Venezuela, including its agencies and instrumentalities as well as any...more
On 4 June 2019 the Trump administration implemented certain regulatory changes first announced on 17 April 2019 by National Security Advisor Ambassador John Bolton in a foreign policy address regarding the Trump...more
On 28 January 2019, the Department of Treasury’s Office of Foreign Assets Control (OFAC) designated Petróleos de Venezuela, S.A. (PdVSA) as a Specially Designated National (SDN) for operating in the oil sector of the...more
The past two weeks have entailed a flurry of sanctions developments related to Russia, including the issuance of a new executive order, and the designation of a number of entities by the U.S. Department of the Treasury's...more
Declaring that it is “defective at its core,” on 8 May 2018, President Trump announced that the United States would withdraw from the Iran nuclear deal and begin re-imposing sanctions that were lifted pursuant to U.S....more
On Monday, 29 January, the U.S. Treasury Department submitted an unclassified report to Congress concerning significant senior political figures and oligarchs in the Russian Federation and Russian parastatal entities.
...more
On December 20, 2017, President Trump issued Executive Order 13818 implementing the Global Magnitsky Act, and the Office of Foreign Assets Control (OFAC) issued the first designations responsive to this statute.
...more
Press reports indicate that President Trump intends to “de-certify” the Iran nuclear deal this week. In practical terms, that means he would refuse to re-certify one or more statutory elements of a law passed by the U.S....more
On Tuesday, July 25, the U.S. House of Representatives passed H.R. 3364, the Countering America’s Adversaries Through Sanctions Act by a vote of 419-3.
There is some uncertainty, but the legislation is expected to be...more
On July 17, the Department of State communicated to Congress that Iran remains in compliance with its obligations under the Joint Comprehensive Plan of Action (JCPOA), the nuclear agreement reached over Iran’s nuclear program...more
On Friday, 16 June 2017, President Trump made his first major foray into U.S. - Cuban relations since assuming office. While it was a radical departure in tone from his predecessor, the changes he announced appear to leave...more
While much attention has been focused on the Trump Administration's recent actions targeting imports of metals, lumber, and other commodities, the Administration has also steadily ramped up its activities in the trade...more
5/1/2017
/ Chemical Weapons ,
Executive Orders ,
Exports ,
Exxon Mobil ,
Imports ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
National Security ,
Offshore Drilling ,
Oil & Gas ,
Russia ,
Syria ,
Trump Administration ,
U.S. Treasury
On Friday, February 3, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) announced it was designating 25 entities and individuals as Specially Designated Nationals (SDNs) for their involvement in...more
2/14/2017
/ Foreign Policy ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
National Security ,
Nuclear Weapons ,
Office of Foreign Assets Control (OFAC) ,
Procurement Guidelines ,
SDN List ,
Terrorist Threats ,
Trump Administration ,
U.S. Treasury ,
WMD
On Friday, January 27, 2017, President Trump signed an executive order temporarily barring the entry of refugees and citizens from certain countries into the United States. The order, "Protecting the Nation from Foreign...more
1/31/2017
/ Department of Homeland Security (DHS) ,
Dual Citizenship ,
Executive Orders ,
Foreign Nationals ,
Green Cards ,
Immigrants ,
Immigration Procedures ,
Immigration Reform ,
Iran ,
Iraq ,
Libya ,
Somalia ,
Sudan ,
Syria ,
Travel Ban ,
Trump Administration ,
Visas ,
Yemen