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US Outbound Investment Enforcement Is Now Live

Despite uncertainty amid talks of reforming the Outbound Investment Security Program (OISP), the US Department of the Treasury is already actively pursuing enforcement actions against transaction parties that may have...more

The America First Investment Policy

On February 21, 2025, the White House issued a memorandum announcing the America First Investment Policy (AFIP) and directing executive branch departments and agencies to promulgate rules and regulations to promote America’s...more

Assessing the Impact of the Outbound Investment Security Program on Debt Transactions

On January 2, 2025, the US Department of the Treasury implemented the new Outbound Investment Security Program (OISP), which prohibits or imposes notification requirements on certain investments by US persons in persons that...more

Outbound Investment Security Program: Final Rule

On October 28, 2024, the US Department of the Treasury issued final regulations implementing the Executive Order on Addressing United States Investments in Certain National Security Technologies and Products in Countries of...more

New License Exception Authorizes Exports of Previously Restricted Medical Devices and Related Items to Russia, Belarus, Occupied...

The US Department of Commerce’s Bureau of Industry and Security (BIS) added a new License Exception for Medical Devices (License Exception MED), effective April 29, 2024, authorizing exports, reexports and transfers of...more

New US Law Doubles Statute of Limitations for Sanctions Violations

On April 24, 2024, President Joe Biden signed into law HR 815, which primarily provides supplemental emergency appropriations relating to ongoing conflicts in Ukraine, Israel and Taiwan. Although principally focused on an...more

NSD’s Revised Enforcement Policy for Business Organizations Incentivizes Voluntary Self-Disclosures in M&A Context

Companies engaged in mergers & acquisitions activities should take note of the revised voluntary self-disclosure policy (VSD Policy) of the National Security Division (NSD) of the US Department of Justice, released on March...more

Tri-Seal Compliance Note Highlights Broad Reach of US Trade Controls, Obligations of Non-US Persons

On 6 March 2024, the US Department of Commerce, Department of the Treasury and Department of Justice issued a Tri-Seal Compliance Note (compliance note) advising foreign-based companies and individuals to assess their...more

Export Control Reminder: Encryption Reporting Deadline Is February 1, 2023

The deadline for submitting reports regarding certain exports of encryption items under the US Export Administration Regulations (EAR) is February 1, 2023. Two types of reports are subject to the deadline...more

Export Control Reminder: Semiannual Encryption Reporting Deadline Is August 1, 2022

August 1, 2022 is the deadline for submitting semiannual reports for certain encryption items exported or re-exported between January 1 and June 30, 2022, pursuant to paragraphs (b)(2) and (b)(3)(iii) of License Exception ENC...more

8/1/2022  /  ECCNs , Encryption , Export Controls , Exports

Evolving US, UK and EU Sanctions and Export Controls Target Russia for Ukraine Invasion

In response to Russia’s invasion of Ukraine in February 2022, the United States, with support from its allies including the United Kingdom and the European Union, has imposed a complex mix of financial sanctions and export...more

US Commerce Department Adds 33 Chinese Entities to Unverified List

On February 8, 2022, the US Department of Commerce’s Bureau of Industry and Security (BIS) added 33 Chinese entities to the agency’s Unverified List (UVL). The UVL does not fully prohibit transactions with the designated...more

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