On May 13, 2025, the Department of Commerce’s Bureau of Industry and Security (BIS) announced a recission of the Biden administration’s January 15, 2025 Artificial Intelligence Diffusion Interim Final Rule (“AI Diffusion...more
6/18/2025
/ Artificial Intelligence ,
Biden Administration ,
Bureau of Industry and Security (BIS) ,
China ,
Due Diligence ,
ECCNs ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Export Controls ,
IaaS ,
New Regulations ,
Regulatory Reform ,
Semiconductors ,
Trump Administration ,
United Arab Emirates (UAE)
On May 23, 2025, 10 days after President Trump announced his directive to lift U.S. sanctions on Syria during his visit to Saudia Arabia last month, the U.S. Department of the Treasury’s Office of Foreign Assets Control...more
6/12/2025
/ Bureau of Industry and Security (BIS) ,
CAATSA ,
CFIUS ,
Economic Sanctions ,
EU ,
Export Controls ,
International Trade ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Regulatory Reform ,
SDN List ,
Syria ,
Trump Administration ,
U.S. Treasury ,
UK
On May 28, 2025, the U.S. Court of International Trade (CIT) ruled that President Trump lacks authority under the International Emergency Economic Powers Act (IEEPA) to impose his most sweeping tariffs against U.S. trading...more
6/9/2025
/ Appeals ,
Appellate Courts ,
Canada ,
China ,
Constitutional Challenges ,
Court of International Trade ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Judicial Authority ,
Mexico ,
Retaliatory Tariffs ,
Section 232 ,
Section 301 ,
Statutory Interpretation ,
Tariffs ,
Trump Administration ,
United States-Mexico-Canada Agreement (USMCA) ,
US Trade Policies
On May 12, 2025, the Criminal Division of the U.S. Department of Justice (DOJ) revised its Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP) and Corporate Whistleblower Awards Pilot Program (Whistleblower...more
6/2/2025
/ Anti-Corruption ,
Biden Administration ,
Compliance ,
Corporate Governance ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
FCPA Corporate Enforcement Policy (CEP) ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
New Guidance ,
Non-Prosecution Agreements ,
Penalties ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
Whistleblowers
Since the mid-1990s, the Executive Branch has sought to target foreign terrorist organizations, and those individuals and organizations supporting them, in order to degrade their funding and support. Organizations and...more
5/20/2025
/ CFIUS ,
Criminal Prosecution ,
Economic Sanctions ,
Enforcement Actions ,
Financial Crimes ,
Government Agencies ,
International Emergency Economic Powers Act (IEEPA) ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Terrorism Funding ,
White Collar Crimes
On April 30, 2025, the Department of Justice (DOJ) National Security Division (NSD) announced its second-ever public declination under its updated corporate voluntary self-disclosure (VSD) policy when it declined to charge...more
As a part of the new administration’s broader effort to add regulatory requirements and scrutiny to institutions of higher education, on April 23, 2025, President Trump issued an Executive Order (EO) on Transparency Regarding...more
Key Takeaways-
• Recent Foreign Terrorist Organization (FTO) designations affecting cartels and transnational criminal organizations (TCOs) have equipped the Department of Justice (DOJ) with a powerful source of authority...more
As the third month of the second Trump administration comes to a close, the lack of any public enforcement action by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has sanctions watchers...more
4/25/2025
/ Corporate Counsel ,
Due Diligence ,
Economic Sanctions ,
Enforcement Actions ,
Iran ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Popular ,
Risk Management ,
Russia ,
Settlement ,
Trump Administration ,
Ukraine
The United States has for decades utilized its economic clout to pursue sanctions against rogue governments and regimes, terrorists, narcotics traffickers, and human rights abusers. Now, with roughly half a year left in his...more
On April 30, 2020, the U.S. Small Business Administration (SBA) issued a sixth interim final rule on the SBA’s Paycheck Protection Program (PPP), one of the relief programs available under the Coronavirus Aid, Relief, and...more
On Thursday, April 23, 2020, the U.S. House of Representatives voted in favor of the $484 billion relief package that passed in the Senate earlier this week. Once signed into law, the legislation will revive the Small...more
Haima Marlier, David Newman, and Haydn Forrest authored an article for Law360 discussing the increased scrutiny related to insider trading in the time of the coronavirus outbreak, analyzing the investigation into Senator...more
In response to the COVID-19 public health emergency, which has dramatically affected global commerce, the U.S. healthcare system, and the U.S. economy, on March 27, 2020, the President signed into law the Coronavirus Aid,...more
It’s no secret that Iran has been one of the hardest hit countries by COVID-19 (commonly referred to as the “coronavirus”). As in other countries, this outbreak has strained Iran’s healthcare system and has instigated a surge...more
The cover of this week’s issue of The Economist shows a picture of the globe with a “Closed” sign hanging over it. So what happens when global commerce grinds nearly to a halt, as appears to be happening? And what happens to...more
On Thursday evening, Governor Newsom issued an executive order (the “State Order”) that expanded the shelter-in-place orders already in place in each of the nine San Francisco Bay Area counties broadly directing all...more
On February 18, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) added Rosneft Trading S.A. (“Rosneft Trading”) and its president to the agency’s List of Specially Designated Nationals and...more
Over the past few days, we here at MoFo’s National Security Practice Group have outlined the extraordinary pace of activity that the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) maintained in 2019 as...more
As we mentioned in the first part of our U.S. Sanctions Year in Review series, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) had an extraordinarily busy year in 2019, and its enforcement activity...more
As we enter 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) may need time to catch its breath after an exceptionally busy year. 2019 showed us that the Trump Administration continues to rely on...more
The World Health Organization (WHO) has now declared the current outbreak of the new coronavirus first identified in Wuhan, Hubei Province, China as a “Public Health Emergency of International Concern.” As more countries...more
On December 13, 2019, the Department of Justice’s National Security Division (“NSD”) announced a revised policy to encourage voluntary self-disclosures (“VSDs”) of criminal violations of export control and sanctions laws. The...more
As it nears the end of the calendar and legislative year, Congress is preparing to take long-awaited action to kill Russia’s Nord Stream 2 and TurkStream natural gas pipeline projects – months before Nord Stream 2’s...more
As another sign of the escalating tensions between the United States and China, in addition to the long-running trade war, China this week suspended visits to Hong Kong by the U.S. military and vowed to impose sanctions on a...more