On December 7, 2020, U.S. Customs and Border Protection (CBP) modified an existing Withhold Release Order (WRO) on bone black produced in Brazil by Bonechar Carvão Ativado do Brasil Ltda (Bonechar). As a result of this...more
On October 1, 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) released an advisory regarding potential sanctions risks related to facilitating ransomware payments...
OFAC is the federal...more
10/16/2020
/ Cyber Attacks ,
Cyber Threats ,
Cybersecurity ,
Data Breach ,
FCPA Guidance ,
Hackers ,
International Emergency Economic Powers Act (IEEPA) ,
Malware ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Ransomware ,
Risk Factors ,
Sanctions ,
SDN List ,
TWEA
On August 12, 2020, the SEC Office of Compliance Inspections and Examinations (OCIE) published a Risk Alert that identifies potential issues related to the COVID-19 pandemic for SEC-registered investment advisers and...more
9/16/2020
/ Broker-Dealer ,
Business Continuity Plans ,
Business Operations ,
Compliance ,
Coronavirus/COVID-19 ,
Data Protection ,
Fees ,
Investment Adviser ,
Investment Fraud ,
OCIE ,
Personally Identifiable Information ,
Policies and Procedures ,
Popular ,
Remote Working ,
Risk Alert ,
Securities and Exchange Commission (SEC) ,
Supervision
Hong Kong Updates and Alerts -
New Restrictions on Exports to Hong Kong – License Exceptions for Hong Kong Suspended -
On June 29, 2020, the State Department announced that the U.S. will end the export of U.S.-origin...more
8/7/2020
/ 5G Network ,
Bureau of Industry and Security (BIS) ,
CAATSA ,
CFIUS ,
China ,
Cross-Border ,
Cuba ,
Department of Justice (DOJ) ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Exports ,
FCPA Resource Guide ,
Final Rules ,
Hong Kong ,
Hong Kong Autonomy Act (HKAA) ,
Huawei ,
International Chamber of Commerce (ICC) ,
Iran Sanctions ,
Military End Use ,
New Rules ,
Nicaragua ,
Russia ,
Sanctions ,
Securities and Exchange Commission (SEC) ,
State-Owned Enterprises ,
Syria ,
Trump Administration ,
Venezuela
Proposed Rules on CFIUS Mandatory Declarations Released: No More NAICS Codes!
On May 21, 2020, the Department of the Treasury released a proposed rule that would modify the requirements for Committee on Foreign Investment...more
6/11/2020
/ Bulk Electric System ,
CFIUS ,
China ,
Cross-Border Transactions ,
Energy Sector ,
Export Controls ,
Foreign Investment ,
Huawei ,
Human Rights Act ,
Iran Sanctions ,
Metals ,
Money Laundering ,
NAICS ,
Nicaragua ,
North Korea ,
Proposed Rules ,
Sanctions ,
Zimbabwe
Foley Hoag’s Trade Sanctions & Export Controls Practice offers experienced, proactive regulatory advice to help clients avoid regulatory compliance missteps and to prevail in official proceedings.
Included in this Issue:...more
5/15/2020
/ Coronavirus/COVID-19 ,
Cross-Border ,
Customs and Border Protection ,
Department of Health and Human Services (HHS) ,
Directorate of Defense Trade Controls (DDTC) ,
FEMA ,
Food and Drug Administration (FDA) ,
Immigration ,
International Trade ,
New Guidance ,
Personal Protective Equipment ,
Preventive Health Care ,
Supply Chain ,
World Customs Organization
Foley Hoag LLP has formed a firm-wide, multi-disciplinary task force dedicated to client matters related to the novel coronavirus (COVID-19). In the rapidly changing global health environment, Foley Hoag will provide clients...more
5/12/2020
/ Compliance ,
Cross-Border ,
Cross-Border Transactions ,
Executive Orders ,
FCC ,
Office of Foreign Assets Control (OFAC) ,
Securities and Exchange Commission (SEC) ,
Team Telecom ,
Telecommunications ,
Transitional Arrangements ,
Trump Administration
Foley Hoag’s Trade Sanctions & Export Controls Practice offers experienced, proactive regulatory advice to help clients avoid regulatory compliance missteps and to prevail in official proceedings.
Included in this...more
Foley Hoag’s Trade Sanctions & Export Controls Practice offers experienced, proactive regulatory advice to help clients avoid regulatory compliance missteps and to prevail in official proceedings…
Included in this Issue:
•...more
Foley Hoag LLP has formed a firm-wide, multi-disciplinary task force dedicated to client matters related to the novel coronavirus (COVID-19). In the rapidly changing global health environment, Foley Hoag will provide clients...more
The World Trade Organization (WTO) has formed a taskforce in response to the COVID-19 pandemic and is tracking the latest disruptions to international trade on their new webpage. The webpage includes FAQs, updates from WTO...more
Updates from March 11 to March 25, 2020 -
Key Takeaways:
Supply chain disruption has begun on some fronts that are not directly related to the healthcare and medical fields, and is anticipated to continue as the effects...more
3/31/2020
/ Business Closures ,
Coronavirus/COVID-19 ,
Customs and Border Protection ,
Defense Sector ,
EU ,
Exports ,
Federal Bans ,
Filing Requirements ,
Food and Drug Administration (FDA) ,
International Trade Commission (ITC) ,
Medical Devices ,
Member State ,
Personal Protective Equipment ,
Section 301 ,
Social Distancing ,
Supply Chain ,
Trade Agreements ,
USTR ,
Virus Testing
Huawei Charged in Racketeering Conspiracy and Conspiracy to Steal Trade Secrets; Temporary General License Extended –
On February 13, 2020, Huawei Technologies Co. Ltd. (Huawei) and two of its U.S. subsidiaries were...more
3/17/2020
/ Airbus ,
Bureau of Industry and Security (BIS) ,
Compliance ,
Criminal Conspiracy ,
Criminal Prosecution ,
Cross-Border ,
Cross-Border Transactions ,
Economic Sanctions ,
General Licenses ,
Huawei ,
Iran ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
Transitional Arrangements ,
U.S. Treasury ,
UK ,
UK Brexit ,
Venezuela
New CFIUS Regulations Released: Final Rules Impact Foreign Investment in Technology, Infrastructure, and Data (TID) Businesses and Real Estate -
On January 13, 2020, the Department of the Treasury issued final regulations...more
2/6/2020
/ Artificial Intelligence ,
Bureau of Industry and Security (BIS) ,
CFIUS ,
Critical Infrastructure Sectors ,
Cross-Border Transactions ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Investment ,
Office of Foreign Assets Control (OFAC) ,
Technology Sector
FAQs on How New Rules Impact Foreign Investment in U.S. Businesses -
When do the new CFIUS regulations go into effect? -
On January 13, 2020, the Department of the Treasury issued final regulations (31 CFR §§800, 802)...more
This is the sixth in our start-of-year series examining important trends in white collar law and investigations in the coming year. Our previous entry discussed enforcement by the Massachusetts Attorney General’s Office in...more
1/24/2020
/ Bureau of Industry and Security (BIS) ,
Chief Compliance Officers ,
China ,
Compliance ,
Corporate Counsel ,
Cuba ,
Customs and Border Protection ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Entity List ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Hong Kong ,
Huawei ,
Human Rights ,
Information Technology ,
Iran Sanctions ,
Magnitsky Act ,
National Security ,
New Guidance ,
New Regulations ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Software ,
Syria ,
Technology Sector ,
Turkey ,
U.S. Treasury ,
US Department of State ,
Venezuela ,
Voluntary Disclosure ,
White Collar Crimes
DOJ Issues Revised Export Control and Sanctions Enforcement Policy for Business Organizations Providing Clear Guidance on the Benefits of Self-Disclosing Violations -
On December 13, 2019, the Department of Justice (DOJ)...more
In December, the Department of Justice (DOJ) announced the release of a new policy for business organizations regarding voluntary self-disclosures of export control and sanctions violations. The new Policy makes explicit that...more
Alert for Information and Communications Technology and Services Industries: Proposed New Rule Implements Unprecedented Regime to Review and Restrict Transactions -
The Department of Commerce (DOC) is accepting comments...more
Additional Restrictions on Exports to Cuba -
On October 15, 2019, the Department of Commerce (DOC) amended the Export Administration Regulation (EAR) to further restrict the export and reexport of items to Cuba. The...more
11/25/2019
/ CFIUS ,
Compliance ,
Cross-Border Transactions ,
Cuba ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Exports ,
Foreign Investment ,
Human Rights ,
Magnitsky Act ,
Withhold Release Orders (WROs)