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Trump administration's focus on immigration enforcement means companies should be prepared

Robust immigration enforcement was a consistent theme that the Republican party sounded during the presidential campaign. Since taking office, the second Trump administration has surged into action with remarkable speed,...more

OFAC takes the position that certain kinds of SDN participation in public conferences is not a prohibited service under U.S....

The U.S. Department of Treasury’s Office of Foreign Assets Control issued a formal guidance letter stating that certain kinds of Specially Designated Nationals could speak at a public conference to share their individual...more

U.S. Department of Commerce expands controls on advanced semiconductors and establishes new controls on closed AI model weights

The new interim final rule imposes new global licensing requirements for ECCNs 3A090.a, 4A090.a, and corresponding .z items; controls for closed AI model weights; updated data center validated end-user authorizations;...more

The United States and the United Kingdom impose new sanctions against the Russian energy sector

New U.S. and UK sanctions target Russia’s energy sector and supporting infrastructure. On January 10, 2025, the United States and the United Kingdom imposed additional sanctions against Russia, with a focus on its energy...more

Doing Business in the United States 2025

The U.S. is one of the easiest jurisdictions in the world in which to do business1 and continues to be the world’s top destination for foreign direct investment.2 Regulatory barriers are generally low, establishing a branch...more

U.S. Appeals Court limits OFAC’s sanctions authority in cryptocurrency mixer case

The Fifth Circuit held that Tornado Cash, open-source computer code known as an immutable “smart contract”, is not “property” and thus cannot be subject to blocking sanctions pursuant to IEEPA and EO 13694....more

US announces sanctions against Chinese entities assisting in Russian drone development

The Office of Foreign Assets Control of the US Department of Treasury imposed sanctions against three private entities and one individual for assisting in the development and production of Russia’s Garpiya series long-range...more

Significant new measures against Russia issued by US Departments of Treasury, State, and Commerce

On 12 June 2024, the US Departments of Treasury, State, and Commerce imposed new restrictions targeting Russia, including: (i) restricting the provision of certain information technology and software services to Russia...more

OFAC issues interim final rule amending blocked property and other reporting requirements

The Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued an interim final rule set to take effect August 8, 2024, which amends the Reporting, Procedures, and Penalties Regulations (the “Regulations”)...more

Statute of limitations extended for violations of U.S. sanctions

Congress has doubled the statute of limitations for violations of most U.S. sanctions programs administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control.  Companies should be aware of the...more

BIS Issues License Exception MED for Russia, Belarus, Crimea, and covered regions of Ukraine

On April 29, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a final rule to add a new license exception for medical devices (License Exception MED) to authorize the export, reexport, and...more

U.S. Department of Commerce issues new resource to facilitate antiboycott compliance

On 28 March, the U.S. Commerce Department, Bureau of Industry and Security (BIS) published a list of entities that have been identified as having made a boycott-related request in order to help U.S. companies, including...more

Deepened UK-U.S. collaboration: Celebrating the first anniversary of the OFAC–OFSI partnership

October 2023 marked the first anniversary of the enhanced partnership between the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the United Kingdom Office of Financial Sanctions...more

U.S., EU, and UK expand sanctions to mark the second anniversary of Russia’s war in Ukraine

Following the death of political activist Aleksey Navalny and to mark the second anniversary of Russia’s invasion of Ukraine, the United States, EU and UK adopted a series of amendments to their respective economic sanctions...more

FinCEN proposes expanding Bank Secrecy Act requirements to certain investment advisers

On February 13, 2024, U.S. Department of the Treasury’s Financial Crimes Enforcement Network issued a Notice of Proposed Rulemaking seeking to expand the Bank Secrecy Act’s definition of “financial institution” to include...more

New Russia sanctions target foreign financial institutions and imports of certain products

On December 22, 2023, President Biden issued a new Russia-related Executive Order (“EO”) targeting foreign financial institutions (“FFIs”) that support Russia’s military-industrial base. The new EO allows the U.S. government...more

BIS Issues Three New Rules To Ease Certain Export Licensing Requirements

On December 8, 2023, the Bureau of Industry and Security (BIS) issued three separate rules to amend the Export Administration Regulations (EAR) to liberalize several categories of export licensing requirements and make...more

U.S. Corporate Transparency Act beneficial ownership reporting regulations take effect January 2024

The U.S. Congress enacted the Corporate Transparency Act (CTA) in 2020. The CTA for the first time created a federal obligation to report beneficial ownership information for most U.S. entities (and foreign entities doing...more

2023 Doing Business in the United States

The U.S. is one of the easiest jurisdictions in the world in which to do business and continues to be the world’s top destination for foreign direct investment. Regulatory barriers are generally low, establishing a branch...more

U.S. eases Venezuela sanctions following electoral roadmap agreement

In recognition of political progress between the Government of Venezuela and opposition parties—notably, the signing of an electoral roadmap agreement between the Unitary Platform and representatives of Nicolas Maduro--the...more

Significant new sanctions and export control measures by the US government against Russia

On May 19, 2023, the US Department of Treasury, State, and Commerce imposed the most significant tranche of sanctions and export control measures in several months. The measures included (i) new designations on the Specially...more

Aerospace & Defense Insights | DDTC outlines expectations for global compliance

Through Aerospace & Defense Insights, we share with you the top legal and political issues affecting the aerospace and defense (A&D) industry. Our A&D industry team monitors the latest developments to help our clients stay in...more

U.S. implements new export controls on toxins, plant pathogens and biological equipment

The United States Department of Commerce’s Bureau of Industry and Security has issued regulations to amend the Export Administration Regulations to implement changes to controls of certain viruses, marine toxins, plant...more

Update: U.S. sanctions regarding Russian-origin crude oil and price cap

On 2 December 2022, the US Department of the Treasury issued a press release announcing a $60/barrel price cap that will apply to the prohibition on US persons from engaging in a broad range of services related to the...more

OFAC releases new guidance on the price cap policy for crude oil of Russian Federation origin

The U.S. Department of the Treasury’s Office of Foreign Assets Control published a Determination pursuant to Executive Order 14071 that implements the price cap policy for crude oil of Russian Federation origin. To complement...more

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