On February 10, 2025, President Trump signed an Executive Order (E.O.) directing a shift in the enforcement of the Foreign Corrupt Practices Act (FCPA). The order effectively pauses new FCPA investigations and enforcement...more
2/13/2025
/ Anti-Corruption ,
China ,
Compliance ,
Corporate Counsel ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
National Security ,
Trump Administration
1. What? Tariff Rates and Legal Authority -
President Trump signed three executive orders imposing new tariffs against Canada, Mexico, and China, following through on prior campaign and post-inauguration promises. While...more
2/4/2025
/ Canada ,
China ,
Compliance ,
Executive Orders ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Mexico ,
National Security ,
Recordkeeping Requirements ,
Section 301 ,
Supply Chain ,
Tariffs
As President Trump begins his second term, the absence of tariffs among the more than 200 executive orders signed on his first day in office was a notable deviation from expectations. However, the President announced plans to...more
1/23/2025
/ Canada ,
Compliance ,
Corporate Counsel ,
Executive Orders ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
International Trade Commission (ITC) ,
Mexico ,
National Security ,
Section 301 ,
Tariff Act of 1930 ,
Tariffs ,
Trade Act of 1974 ,
Trade Expansion Act of 1962 ,
Trump Administration ,
US Trade Policies
The U.S. Government recently announced the largest round of sanctions against the Russian Federation (Russia) since the invasion of Ukraine two years ago. This multi-agency effort enacted over 500 sanctions against foreign...more
3/7/2024
/ Bureau of Industry and Security (BIS) ,
Due Diligence ,
Economic Sanctions ,
EU ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Financial Institutions ,
Military Conflict ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanction Violations ,
Supply Chain ,
UK ,
Ukraine
In recent memory, enforcement of the Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”) regulations has been mostly limited and sporadic. But recently, the U.S. government is reviving and...more
1/22/2024
/ Acquisitions ,
Buyers ,
CFIUS ,
Compliance ,
Due Diligence ,
Enforcement ,
Executive Orders ,
Export Controls ,
FIRRMA ,
Foreign Investment ,
Infrastructure ,
Mergers ,
Sellers ,
U.S. Treasury
The much anticipated Executive Order (the “E.O.”) on outbound investments directed at the Chinese technology sector was finally released on August 9, 2023. Citing the “unusual and extraordinary threat to national security”...more
Although not receiving much media attention, in October 2022, the nationwide injunction on Executive Order 14042, Ensuring Adequate COVID-19 Safety Protocols for Federal Contractors (the “EO”) was lifted. The injunction,...more
As the war continues in Ukraine, pressure from the European Union (“E.U.”) and the United States (“U.S.”) continue to mount on Russia’s global interests. On April 6, 2022, the United States issued Executive Order 14071,...more
As the Russia-Ukraine conflict escalates, the U.S. Government has started to implement new sanctions on Russian entities on top of the ones that already existed. On February 21, 2022, the Executive Order on Blocking Property...more
2/25/2022
/ Biden Administration ,
Executive Orders ,
Exports ,
Foreign Policy ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Russia ,
Sanctions ,
SDN List ,
Supply Chain ,
Ukraine
On November 4, 2021, the White House extended the deadline for covered federal contractors to comply with the COVID-19 vaccine mandate established by the Safer Federal Workforce Task Force. Now, instead of being in compliance...more
11/12/2021
/ Biden Administration ,
Coronavirus/COVID-19 ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Dodd-Frank ,
Employer Mandates ,
Executive Orders ,
Federal Acquisition Regulations (FAR) ,
Federal Contractors ,
OSHA ,
Vaccinations ,
Workplace Safety
Late yesterday, the Civilian Agency Acquisition Council (CAAC) released guidance prescribing a class deviation from the Federal Acquisition Regulations (FAR) in order to implement President Biden’s vaccine mandate for certain...more
10/4/2021
/ Biden Administration ,
Coronavirus/COVID-19 ,
Employer Mandates ,
Executive Orders ,
Federal Acquisition Regulations (FAR) ,
Federal Contractors ,
Federal Employees ,
Service Contract Act ,
Subcontractors ,
Vaccinations ,
Virus Testing ,
Workplace Safety
On Monday April 19, 2021, Arizona Governor Doug Ducey signed Executive Order 2021-09 banning vaccine passports in Arizona—also known as digital health passports (“DHPs”). The Executive Order (“EO”) prevents local governments,...more
4/27/2021
/ Arizona ,
Biden Administration ,
Coronavirus/COVID-19 ,
Emergency Use Authorization (EUA) ,
Equal Employment Opportunity Commission (EEOC) ,
Executive Orders ,
Food and Drug Administration (FDA) ,
Governor Ducey ,
State Bans ,
Vaccinations ,
Vaccine Passports
On March 7, 2021, President Biden signed an executive order aiming to increase voters’ access to elections. The executive order serves as an “initial step” in President Biden’s plan to work with Congress to attempt to...more
On January 19, 2021, the Department of Defense (DoD), the General Services Administration, and the National Aeronautics and Space Administration issued a final rule amending the Federal Acquisition Regulation (FAR) concerning...more
On January 14, 2021, the U.S. Department of Commerce issued an interim final rule to address national security, economic security, and public health and safety concerns related to Information and Communications Technology and...more
1/20/2021
/ CFIUS ,
China ,
Cuba ,
Executive Orders ,
Export Controls ,
Foreign Adversaries ,
Infrastructure ,
Interim Final Rules (IFR) ,
Iran Sanctions ,
National Security ,
Russia ,
US Trade Policies ,
Venezuela
As with any presidential (or governor) transition, significant changes occur in regard to the executive offices’ regulatory enforcement priorities and changes from the previous administration. Because the majority of rules...more
On November 12, 2020, President Donald Trump signed an executive order prohibiting “United States persons” from engaging in “transactions” in securities of “Chinese Communist military companies.” The order marks another...more
On March 19, Governor Doug Ducey issued an executive order delaying “all nonessential or elective surgeries, including elective dental surgeries, that utilize personal protective equipment or ventilators” with the purpose of...more