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National Security: Trump Orders Review of Export, Supply Chain, ‘Reverse CFIUS’ Rules

Several of President Donald Trump’s initial actions — from an executive order instituting a new artificial intelligence (AI) policy framework, to those directing the use of the U.S. military to provide border security, the...more

US Commerce Dept. Rule Expands Licensing Requirements for AI-Related Materials

On January 13, 2025, the Department of Commerce, Bureau of Industry and Security (BIS) released an interim final rule establishing (i) expanded export licensing requirements for the export of advanced computing integrated...more

Political Changes Are Unlikely To Fundamentally Alter Key Sanctions

Key Points - - Political transitions in the West notwithstanding, we expect economic sanctions to remain a key response to geopolitical issues. - Current sanctions policy priorities are unlikely to shift markedly in...more

In the US and Europe, Export and Import Controls May Be Expanded

Key Points - - Under the second Trump administration, the U.S. is expected to increase export control restrictions on China, particularly in the semiconductor sector, as well as to expand other China-related national...more

Most AI National Security Regs Likely To Remain in Place Under the Next Administration

With the rapid commercialization of artificial intelligence (AI) technology, the Biden administration has been grappling with its implications, including its potential impact on national security. Several departments have...more

The Sanctions Puzzle: Key Areas To Watch in 2025 and Beyond

The past weeks and months have brought about tremendous political change in the West, as we move toward a new U.S. administration, a new College of Commissioners in Brussels and a new Polish presidency of the Council of the...more

REPO for Ukrainians Act Provides for the ‘Repurposing’ of Seized Russian Sovereign Assets

On April 24, 2024, President Joe Biden signed into law a high-profile package of national security legislation (Public Law 118-50). While most press reports focused on the spending elements of the package (appropriating funds...more

BIS Reduces Licensing Requirements on Exports to Australia and the UK

In an interim final rule published on April 19, 2024 (New Rule), the Department of Commerce, Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) to reduce licensing requirements on...more

New BIS Rule Imposes Stringent Export Control Restrictions Targeting Large Number of OFAC-Sanctioned Parties

On March 21, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published a final rule amending the Export Administration Regulations (EAR) by imposing “end user” export control restrictions against...more

BIS Publishes Revisions to Export Administration Regulations, Loosening Restrictions on Certain Cameras and Imposing Controls on...

On February 23, 2024, the Department of Commerce Bureau of Industry and Security (BIS) published revisions to the Export Administration Regulations (EAR), loosening restrictions on the export of certain cameras, optical...more

‘Small Yard and High Fence’: US National Security Restrictions Will Further Impact US-China Trade and Investment Activity in 2024

The economic relationship between China and the U.S. remains one of the most significant in the world, and U.S. and Chinese government leaders have repeatedly signaled their intent to maintain stable trade and commercial...more

BIS Updates October 2022 Semiconductor Export Control Rules

On October 17, 2023, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) released two interim final rules to reinforce and expand controls on (a) advanced semiconductors and related computing items (the...more

US Eases Sanctions on Venezuela in Connection With Electoral Roadmap

On October 18, 2023, following the signing of an electoral roadmap between Venezuela’s Unitary Platform and representatives of the Maduro regime, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC)...more

OFAC Enforcement Action Emphasizes the Importance of Whistleblower Programs

On August 16, 2023, OFAC announced a $660,594 settlement with Construction Specialties Inc. (CS) for alleged violations of the Iranian Transactions and Sanctions Regulations (ITSR). OFAC found that CS’s wholly controlled...more

US Expands Nuclear Export Controls on China

In a rule effective August 11, 2023, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) expanded nuclear nonproliferation controls on China, as part of the U.S. government’s latest efforts to address...more

US Authorities Hammer Home the Importance of Self-Disclosing Sanctions and Export Control Violations

On July 26, 2023, the U.S. Department of Justice’s (DOJ’s) National Security Division (NSD), the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), and the U.S. Department of the Treasury’s Office of Foreign...more

In Coordinated Action, US Authorities Increase Russia-Related Restrictions and Warn About Evasion Risks

Through a series of coordinated actions in May 2023, the United States launched a whole-of-government effort to expand and strengthen enforcement of its sanctions campaign against Russia as the conflict in Ukraine continues...more

US Commerce Department Expands Export Restrictions Targeting Russia and Belarus

On February 24, 2023, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced four new rules expanding restrictions on exports to Russia and Belarus. The revisions to the Export Administration...more

Disparate US, EU and UK Sanctions Rules Complicate Multinationals' Exits From Russia

The withdrawal of Western companies from Russia in the wake of the war in Ukraine has garnered a lot of attention. But the process does not take place overnight, and many foreign companies that have operated in Russia face...more

US, UK and EU Expand and Amend Russian Sanctions, Responding to Purported Annexations of Ukrainian Regions

In light of the recent referendums and purported annexation by Russia of four territories of Ukraine on September 30, 2022, the United States, United Kingdom and European Union have expanded measures and provided additional...more

Executive Order Reinforces CFIUS’ Broad Authority To Identify National Security Risks

On September 15, 2022, President Joe Biden issued an executive order (EO) “on ensuring robust consideration of evolving national security risks” by the Committee on Foreign Investment in the United States (CFIUS or the...more

US Adopts Further Sanctions and Export Controls Targeting Russia

Even though significant sanctions and export controls have already been put in place, the United States recently adopted additional measures targeting key elements of the Russian economy and military industry in response to...more

US, UK and EU Impose New Sanctions and Export Controls on Key Elements of Russian Economy

Since the publication of our March 24, 2022, and March 17, 2022, client alerts, the U.S., U.K. and European Union, among other allied nations, have imposed additional sanctions and export controls on key elements of the...more

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