As Russia continues its war against Ukraine and Ukraine has itself recently opened a new front by capturing Russian territory in its Kursk region, the United States announced on August 23 its latest tranche of sanctions...more
9/6/2024
/ Biden Administration ,
Corporate Counsel ,
Defense Sector ,
Economic Sanctions ,
Export Controls ,
Exports ,
Foreign Policy ,
G7 ,
General Licenses ,
Know Your Customers ,
Office of Foreign Assets Control (OFAC) ,
Record Retention ,
Russia ,
SDN List ,
Statute of Limitations ,
Technology Sector ,
U.S. Commerce Department ,
Ukraine
On February 23, building mainly upon the broad authority of Executive Order 14024 (“EO 14024”)[1] issued by President Joe Biden in 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), the...more
3/5/2024
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Defense Sector ,
Economic Sanctions ,
Export Controls ,
Foreign Policy ,
Foreign Trade Regulations ,
General Licenses ,
Iran ,
Military Conflict ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Ukraine
As the February 2022 Russian invasion of neighboring Ukraine approaches its second anniversary and as Russia has increasingly turned to covert relationships with third country providers to avoid U.S., European Union and other...more
2/6/2024
/ Banking Sector ,
CAPTA List ,
Economic Sanctions ,
Executive Orders ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
Foreign Relations ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia
On January 5, 2023, President Biden ushered in the new year by signing into law the Protecting American Intellectual Property Act of 2022 (“PAIPA”), Pub. Law 117-336.1 PAIPA was passed with considerable bipartisan support in...more
1/23/2023
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Corporate Counsel ,
Economic Sanctions ,
Export-Import Bank of the US ,
Foreign Entities ,
Foreign Persons ,
Intellectual Property Protection ,
International Trade ,
New Legislation ,
Office of Foreign Assets Control (OFAC) ,
Theft ,
Trade Secrets ,
U.S. Commerce Department ,
USPTO
On June 6, 2022, the Office of Foreign Assets Control (“OFAC”) within the U.S. Department of the Treasury announced new Frequently Answered Questions (“FAQs”) that interpret several previous Executive Orders (“EOs”) issued by...more
6/10/2022
/ Accounting ,
Biden Administration ,
Consultants ,
Contract Management ,
Economic Sanctions ,
Executive Orders ,
Export Controls ,
Exports ,
Financial Services Industry ,
Foreign Investment ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Ukraine
The United States has announced yet another round of economic sanctions against Russia that builds on existing sanctions and extends them to new sectors of the Russian economy. The U.S. Department of the Treasury’s Office of...more
5/18/2022
/ Bureau of Industry and Security (BIS) ,
Commerce Control List ,
Consultants ,
Duties ,
Economic Sanctions ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Financial Services Agency ,
General Licenses ,
Imports ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Trade Restrictions
On April 6, 2022, the U.S. Government announced its latest round of sanctions against the Russian Federation in coordination with the European Union (“EU”) and other allies. President Biden issued Executive Order 14071 (“EO...more
4/11/2022
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Most-Favored Nations ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Tariffs ,
Trade Restrictions ,
Ukraine
As part of its expanding sanctions against Russia, the Biden Administration on March 8, 2022, issued Executive Order 14066 (“EO 14066,” see here) to bar imports into the United States of Russian crude oil, petroleum;...more
3/14/2022
/ Biden Administration ,
Blocked Entities ,
Blocked Person ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Policy ,
General Licenses ,
Imports ,
Most-Favored Nations ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Tariffs ,
Ukraine
On February 24, 25 and 28, the United States broadened its economic sanctions against Russia in response to its full-scale military invasion of Ukraine. As the Biden Administration had promised in recent weeks, in close...more
3/2/2022
/ Blocked Entities ,
Blocked Person ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Controls ,
Exports ,
Financial Institutions ,
Military End Use ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Software ,
Sovereign Debt ,
Technology ,
Ukraine
The Biden Administration and several allied countries announced on February 22 new economic sanctions on Russia and the separatist territories in Ukraine. In the United States, the sanctions target only certain Russian...more
2/23/2022
/ Biden Administration ,
Blocked Entities ,
Blocked Person ,
Economic Sanctions ,
Embargo ,
Financial Institutions ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
U.S. Treasury ,
Ukraine
President Biden signed into law on December 23 legislation that will, for the first time, require U.S. Customs and Border Protection (“CBP”) to detain all imports that are made wholly or partly in the Xinjiang Uyghur...more
12/29/2021
/ Asia ,
Biden Administration ,
China ,
Customs and Border Protection ,
Department of Homeland Security (DHS) ,
Economic Sanctions ,
Executive Orders ,
Forced Labor ,
Foreign Policy ,
Human Rights ,
Imports ,
National Security ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
Procurement Guidelines ,
Rebuttable Presumptions ,
Reputation Management ,
Risk Management ,
Supply Chain ,
Technology Sector ,
Third-Party ,
Upstream Contracts ,
USTR
The Bureau of Industry and Security (“BIS”) in U.S. Department of Commerce has added 34 more companies to its Entity List in its continued expansion of U.S. export controls to address human rights in the Xinjiang Uyghur...more
7/21/2021
/ Bureau of Industry and Security (BIS) ,
China ,
Customs and Border Protection ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Forced Labor ,
General Licenses ,
Human Rights ,
Iran ,
Military End Use ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
SDN List ,
Tariff Act of 1930 ,
U.S. Commerce Department ,
Withhold Release Orders (WROs)
The Biden Administration last week substantially modified restrictions on U.S. person investments in certain Chinese companies, focusing those new restrictions particularly on entities with ties to the Chinese defense or...more
6/11/2021
/ Biden Administration ,
China ,
Department of Defense (DOD) ,
Executive Orders ,
Military End Use ,
NDAA ,
Office of Foreign Assets Control (OFAC) ,
Publicly-Traded Companies ,
SDN List ,
Surveillance ,
Technology Sector ,
Trump Administration
Effective June 1, 2021, the U.S. Department of the Treasury's Office of Foreign Assets Control (“OFAC”) published new Burmese Sanctions Regulations (“BSR”) that implement President Biden’s February 10, 2021, Executive Order...more
6/7/2021
/ Biden Administration ,
Blocked Person ,
Bureau of Industry and Security (BIS) ,
Burma ,
Economic Sanctions ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
George W Bush ,
ITAR ,
Myanmar ,
Obama Administration ,
Office of Foreign Assets Control (OFAC) ,
President Clinton
On April 8, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) added seven Chinese supercomputer firms and organizations to its Entity List, the agency’s principal export sanctions list. BIS alleges...more
4/26/2021
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
China ,
Customs and Border Protection ,
Entity List ,
Export Administration Regulations (EAR) ,
Exports ,
Forced Labor ,
Huawei ,
Human Rights ,
Imports ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Supply Chain ,
Technology Sector ,
U.S. Commerce Department ,
ZTE
The U.S. District Court for the District of Columbia recently ruled that certain securities trading restrictions will be prevented from going into effect with respect to Xiaomi Corporation (“Xiaomi”) under Section 1237 of the...more
On January 11, Secretary of State Michael Pompeo announced the Trump Administration in its final week in office is returning Cuba to the official State Department list of state sponsors of terrorism. Cuba will thus re-join...more
1/15/2021
/ Biden Administration ,
Cuba ,
Cuban Assets Control Regulations (CACR) ,
Export Administration Regulations (EAR) ,
Foreign Policy ,
Humanitarian Assistance ,
ITAR ,
NGOs ,
Obama Administration ,
Office of Foreign Assets Control (OFAC) ,
State Sponsors of Terrorism ,
Trump Administration ,
TSRA ,
United Nations
On November 12, 2020, President Trump issued Executive Order 139591 (“the Order”) that will shortly bar any U.S. person from “any transaction in publicly traded securities, or any securities that are derivative of, or are...more
11/20/2020
/ China ,
Corporate Counsel ,
Defense Sector ,
Department of Defense (DOD) ,
Divestment ,
Entity List ,
Executive Orders ,
Foreign Investment ,
International Emergency Economic Powers Act (IEEPA) ,
National Security ,
NDAA ,
Office of Foreign Assets Control (OFAC) ,
Publicly-Traded Companies ,
Trump Administration ,
US Trade Policies
On September 14, U.S. Customs and Border Protection (“CBP”) expanded a ban on certain imports from the Xinjiang Uyghur Autonomous Region (“Xinjiang”) in the People’s Republic of China (“PRC”) while saying that it was still...more
On April 17, 2019, the Trump Administration announced that it would now allow plaintiffs to file U.S. federal court cases against individuals and companies that use private property expropriated by the Cuban government after...more
4/23/2019
/ Blocking Statutes ,
Canada ,
Cuba ,
Damages ,
Economic Sanctions ,
EU ,
Expropriation ,
Fair Market Value ,
Foreign Entities ,
Mexico ,
Multinationals ,
Nicaragua ,
Office of Foreign Assets Control (OFAC) ,
Personal Property ,
Secretary of State ,
Trafficking ,
Trump Administration ,
Venezuela
As part of the Agriculture Improvement Act of 2018 (2018 Farm Bill) signed into law by President Trump today, Congress authorized the U.S. Department of Agriculture (USDA) to use federal funds to assist in the marketing of...more
On November 5, 2018, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) will reimpose certain economic sanctions against Iran that had been held in abeyance under the Joint Comprehensive Plan of Action...more