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New Executive Order Restricts U.S. Persons from Trading in Publicly Traded Securities and Derivatives of Certain “Communist...

Key Points - On November 12, 2020, President Trump issued a new EO prohibiting U.S. persons from engaging in transactions in publicly traded securities of certain CCMCs, or any securities that are derivative of, or are...more

New Executive Order Targets Evasion of Customs Laws and International Posts in Light of DHS Action Plan to Combat the Rise of...

- On January 24, 2020, the DHS released a report (“DHS Report”) on the global trade in counterfeit goods, outlining a series of recommendations and actions that should be taken by CBP, ICE and the private sector to combat the...more

OFAC Removes Sanctions on Turkish Ministries and Ministers; U.S. Executive Order Providing a Basis for Sanctions on Turkey Remains...

• On October 23, 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) removed the two Turkish government ministries and three ministers that it added to its Specially Designated Nationals and...more

U.S. Government Authorizes Economic Sanctions on Turkey

• A new Executive Order signed October 14, 2019, authorizes U.S. sanctions related to the military conflict between Turkey and Syria, providing broad authority to impose sanctions against Turkish government agencies,...more

Treasury Imposes Additional Restrictions on Remittances to Cuba and “U-Turn” Transactions

On September 9, 2019, the Trump administration implemented additional U.S. sanctions on Cuba by restricting personal remittances to Cuba and eliminating authorization for U.S. banks to process “U-turn” transactions involving...more

Trump Administration Imposes Broad Sanctions on the Government of Venezuela

• In a further escalation of U.S. sanctions on Venezuela in support of its efforts to oust the regime of Nicolás Maduro, on August 5, 2019, the Trump administration imposed comprehensive sanctions on the Government of...more

Second Round of U.S. Sanctions on Russia Pursuant to the Chemical and Biological Weapons Control Act

• The U.S. Department of State and the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) have imposed three new sanctions on Russia: o Effective August 26, 2019, U.S. banks (as defined below) are...more

Trump Administration Expands Sanctions Targeting Iran’s Industrial Metals Sector

• President Trump issued a new Executive Order (EO) on May 8, 2019—exactly one year after the Trump administration withdrew from the Iran nuclear deal—that widened the scope of existing sanctions targeting the Iranian...more

USTR Increases Section 301 Tariffs on List 3 Products to 25% and Announces Additional Tariffs on Remaining Imports from China

• Following a setback in U.S.-China trade negotiations, the USTR has increased the Section 301 List 3 additional duty rate on $200 billion of Chinese-origin products from 10% to 25% (the rate already in effect for $50 billion...more

Legal and Practical Considerations of the Trump Administration’s Designation of the IRGC as a Foreign Terrorist Organization

• On April 8, 2019, the U.S. government announced its intention to designate the Islamic Revolutionary Guards Corps (IRGC) as a Foreign Terrorist Organization, effective April 15, 2019. This unprecedented action will result...more

OFAC Sanctions Venezuelan State-Owned Energy Company PdVSA, Releases New General Licenses and FAQs for Venezuela Sanctions Regime

• On January 28, 2019, OFAC added the Venezuelan state-owned oil and natural gas company PdVSA to its SDN List. • As a result, U.S. persons are generally prohibited from engaging in transactions with PdVSA and entities that...more

USTR Grants First Product Exclusion Requests from Section 301 Tariffs

• Late on Friday, December 21, 2018, the United States Trade Representative (USTR) quietly announced that it has granted the first product exclusions for products covered by “List 1” of the Section 301 tariffs, effective...more

Iran Sanctions Are Here—Breaking Down What This Means For Business

• As of November 5, 2018, the United States concluded the second of two wind-down periods for re-imposition of U.S. sanctions on Iran following the May 8, 2018, announcement that the United States would cease participation in...more

Trump Administration Sanctions Chinese Entity and its Director in First Imposition of Secondary Sanctions under Section 231 of...

• On September 20, 2018, for the first time, the Trump administration imposed sanctions on a non-U.S. entity and its director for engaging in “significant transactions” with a Russian defense sector company included on the...more

President Trump Issues New Iran Executive Order and Reimposes First Set of Sanctions Following JCPOA Withdrawal

• On August 6, 2018, following President Trump’s decision to withdraw the United States from the JCPOA, the U.S. government announced the reimposition of sanctions on Iran’s automotive sector, its trade in gold and precious...more

OFAC Issues General License 15 Expanding and Extending Authorized Activities with GAZ Group Until October 23, 2018

• On May 22, 2018, OFAC issued General License 15, authorizing U.S. persons to engage in specified transactions related to maintenance or wind-down of operations, contracts or other agreements involving GAZ Group or any...more

President Trump Announces U.S. Withdrawal from JCPOA; U.S. Sanctions on Iran will be Re-imposed Following Wind-Down Periods

• The U.S. government has withdrawn from the Iran Nuclear Deal and reverted sanctions to the status quo ante by re-imposing secondary sanctions that restrict non-U.S. persons from engaging in a broad range of business in...more

OFAC Sanctions Leading Russian Businessmen, Government Officials and Companies

• On April 6, 2018, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) placed seven prominent Russian businessmen, 12 companies, 17 senior Russian government officials, and a state-owned Russian...more

Iran: President Trump Gives the Iran Nuclear Deal a “Last Chance” While Pressuring European Allies to Act

On January 12, 2018, the U.S. administration took three actions relating to Iran - • First, President Trump waived again the application of certain nuclear sanctions while making clear that the United States will refuse to...more

Implementing CAATSA Sanctions on Russia: Approaching Deadlines for “Oligarchs” and “Sovereign Debt” Reports and Recap of Latest...

• The next significant Countering America’s Adversaries Through Sanctions Act (CAATSA)-related deadline for the Trump administration is January 29, 2018, when it must submit reports to Congress on “oligarchs and parastatal...more

Trump Administration Lifts U.S. Sanctions on Sudan; Important Limitations Remain

Based on certain State Department findings, effective October 12, 2017, long-standing U.S. sanctions on the Republic of Sudan administered by OFAC under the Sudan Sanctions Regulations will be terminated, and U.S. persons...more

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