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AI Diffusion Rule Out but BIS Increases Compliance Obligations for Companies

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

Trump Administration Issues Broad Sanctions Relief for Syria, Effectively Lifting 14 Years of Comprehensive Economic Sanctions –...

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

Two Federal Courts Temporarily Strike Down President Trump’s IEEPA Tariffs

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

Terrorism Designations Primer: Process, Authorities, and Recourse

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

DOJ Issues Declination in Corporate Export Control Violations Matter

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

New Executive Order Adds Scrutiny to Universities’ and Other Higher Education Institutions’ Foreign Sources of Funding

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

FTO Designations Heighten Risks for Companies Operating in Latin America / Las designaciones de FTO aumentan los riesgos para las...

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

U.S. Sanctions Enforcement: 2024 Lessons Learned and 2025 Expectations

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

Trump Threatens Sanctions Against The International Criminal Court

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

The SBA Imposes A $20M Limit On PPP Loans For Corporate Groups

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

House Passes A $484 Billion Relief Package; Treasury And The SBA Release New Guidelines For PPP Loans

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

Beware Intense Insider Trading Scrutiny In Current Climate

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

Frequently Asked Questions About The Coronavirus Economic Stabilization Act Of 2020 (CESA)

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

U.S. Sanctions And Iran’s Coronavirus Challenge

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

Excusing Performance In The Wake Of Coronavirus (COVID-19)

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

California Expands Shelter-In-Place Orders Statewide

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

OFAC Targets Rosneft Subsidiary . . . In The Venezuela Sanctions Program?

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

Top 10 Lessons Learned From OFAC’s 2019 Trade-Related Enforcement Actions (OFAC 2019 Year In Review, Part 3)

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

Top 10 Lessons Learned From OFAC's 2019 Financial Institution Enforcement Actions (OFAC 2019 Year In Review Part 2)

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

OFAC 2019 Year In Review (Part 1 of 3)

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

Coronavirus: Steps Employers Should Be Taking

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

DOJ Clarifies Incentives for Voluntary Self-Disclosures of Export Control and Sanctions Violations

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

Congress Pulls the Trigger on Russia’s Nord Stream 2 and TurkStream Pipeline Projects

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

Congress Adds Potential U.S. Sanctions on Hong Kong to Escalating U.S.-China Tensions (Chinese Edition)

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

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