Ongoing efforts to end the war in Ukraine, the construction and demolition of international trade barriers, the reassimilation of Syria into the global economy and other significant geopolitical events continue to dominate...more
11/25/2025
/ Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Extraterritoriality Rules ,
International Emergency Economic Powers Act (IEEPA) ,
Office of Foreign Assets Control (OFAC) ,
Retaliatory Tariffs ,
Sanctions ,
Secondary Sanctions ,
Tariffs ,
U.S. Treasury ,
Whistleblowers
On November 10, 2025, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a final rule, announcing a one-year suspension (the Suspension) of its interim final rule, “Expansion of End-User Controls to...more
11/13/2025
/ Bureau of Industry and Security (BIS) ,
China ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Affiliates ,
Government Agencies ,
Interim Final Rules (IFR) ,
National Security ,
Risk Management ,
Trade Relations ,
Trump Administration ,
U.S. Commerce Department ,
US Trade Policies
On 23 October 2025, the European Union (EU) adopted its 19th package of sanctions against Russia, imposing asset freeze restrictions against 64 individuals and entities, and introducing extensive sectoral sanctions to put...more
11/12/2025
/ Artificial Intelligence ,
Asset Freeze ,
Belarus ,
Belarus Sanctions ,
Cryptoassets ,
Cryptocurrency ,
Defense Sector ,
Economic Sanctions ,
EU ,
Export Controls ,
Financial Services Industry ,
Maritime Transport ,
Natural Gas ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Popular ,
Risk Management ,
Rosneft ,
Russia ,
UK ,
United States
On September 29, 2025, the U.S. Department of Commerce's Bureau of Industry and Security (BIS) released a long-anticipated interim final rule (IFR) that will result in the most dramatic expansion of U.S. export control...more
10/1/2025
/ Bureau of Industry and Security (BIS) ,
Due Diligence ,
Economic Sanctions ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Extraterritoriality Rules ,
Military End Use ,
Office of Foreign Assets Control (OFAC) ,
Supply Chain ,
U.S. Commerce Department
Between 2006 and 2015, the UNSC adopted a series of resolutions applying economic, financial and trade-related sanctions to Iran in response to its nuclear programme. Specific jurisdictions, such as the United States and the...more
9/17/2025
/ Compliance ,
Corporate Counsel ,
Economic Sanctions ,
EU ,
Export Controls ,
Foreign Policy ,
International Trade ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
National Security ,
Popular ,
Risk Management ,
Sanctions ,
Trade Relations ,
UK ,
UN Security Council ,
United Nations
- What is new: The Trump administration’s Working Group on Digital Asset Markets released a comprehensive report outlining some 100 policy and legislative recommendations to position the U.S. as a global leader in digital...more
8/8/2025
/ Blockchain ,
CFTC ,
Cryptocurrency ,
Decentralized Finance (DeFi) ,
Digital Assets ,
FinTech ,
Popular ,
Securities and Exchange Commission (SEC) ,
Stablecoins ,
Taxation ,
Trump Administration
Pursuant to a sweeping new executive order (EO) issued on June 30, 2025, the Trump administration has lifted virtually all U.S. sanctions targeting Syria, shuttered the Syria sanctions program administered by the Office of...more
7/9/2025
/ Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
International Trade ,
Office of Foreign Assets Control (OFAC) ,
Regulatory Reform ,
Syria ,
Trump Administration ,
U.S. Commerce Department
On June 25, 2025, the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued orders identifying three Mexican financial institutions as being of primary money laundering concern in connection with...more
On May 23, 2025, the Trump administration issued a general license (GL) significantly relaxing the patchwork of restrictions on Syria, long a jurisdiction subject to comprehensive sanctions. This regulatory action followed a...more
In a May 12, 2025, memorandum (the May Memorandum) on focus, fairness and efficiency in the fight against white collar crime, the Department of Justice (DOJ) Criminal Division1 again identified the total elimination of...more
On his first day in office, President Trump signed Executive Order 14157 calling for the designation of certain cartels and transnational criminal organizations (TCOs) as foreign terrorist organizations (FTOs) or specially...more
President Trump has taken the first steps toward fulfilling his promise to reverse the Biden administration’s approach to digital assets by issuing an executive order that establishes a framework for fostering the growth of...more
2/10/2025
/ Biden Administration ,
Blockchain ,
CFTC ,
Cryptocurrency ,
Digital Assets ,
Digital Currency ,
Executive Orders ,
Financial Services Industry ,
FinTech ,
Popular ,
Regulatory Agenda ,
Regulatory Reform ,
Revocation ,
Securities and Exchange Commission (SEC) ,
Stablecoins ,
Technology Sector ,
Trump Administration
In the days before former President Joe Biden left office, the U.S. announced two new rounds of sanctions against Russia, including expansive new sanctions against Russia’s energy sector. According to its press release, the...more
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
1/20/2025
/ China ,
Cybersecurity ,
Data Security ,
Economic Sanctions ,
Enforcement Actions ,
EU ,
Export Controls ,
Extraterritoriality Rules ,
Financial Services Industry ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Regulatory Requirements ,
Russia ,
Sanctions ,
UK ,
Whistleblowers ,
White Collar Crimes
On December 26, 2024, the Fifth Circuit merits panel assigned to Texas Top Cop Shop, Inc. v. Garland, No. 24-40792, reinstated a nationwide preliminary injunction enjoining enforcement of the Corporation Transparency Act and...more
12/30/2024
/ Appeals ,
Beneficial Owner ,
Business Entities ,
Business Ownership ,
Corporate Transparency Act ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements ,
Smaller Reporting Companies ,
Stays ,
Vacated
This alert has been updated to reflect FinCEN’s extension of the deadline after the alert was first sent.
On December 23, 2024, after expedited briefing, a three-judge panel of the Fifth Circuit in Texas Top Shop v....more
12/24/2024
/ Beneficial Owner ,
Business Entities ,
Business Ownership ,
Corporate Transparency Act ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements ,
Smaller Reporting Companies ,
Stays ,
Time Extensions
The Corporate Transparency Act (CTA) and its implementing regulations (Regulations) require entities within its scope (reporting companies) to disclose information, including about their beneficial owners, to the U.S....more
12/16/2024
/ Business Ownership ,
Corporate Counsel ,
Corporate Transparency Act ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Reporting Requirements ,
Stays ,
Suspended Judgment ,
Unconstitutional Condition
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
11/13/2024
/ Capital Markets ,
CFIUS ,
China ,
Corporate Counsel ,
Economic Sanctions ,
Enforcement Actions ,
EU ,
Export Controls ,
Extraterritoriality Rules ,
Financial Institutions ,
Middle East ,
National Security ,
Regulatory Requirements ,
Russia ,
Sanctions ,
Tariffs ,
Trump Administration ,
UK ,
Ukraine ,
US Trade Policies ,
Whistleblowers
The Council of the European Union (Council) has updated its EU Best Practices for the Effective Implementation of Restrictive Measures. Published on 3 July 2024, the new version clarifies the threshold for the ownership test...more
The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has proposed a rule (the Proposed Rule) to implement certain aspects of the Anti-Money Laundering Act of 2020 (the AML Act), which updated the...more
7/17/2024
/ AML/CFT ,
Anti-Money Laundering ,
Anti-Terrorism Financing ,
Bank Secrecy Act ,
Financial Institutions ,
Financial Regulatory Reform ,
FinCEN ,
Investment Management ,
Popular ,
Proposed Rules ,
Securities and Exchange Commission (SEC)
On April 24, 2024, President Joe Biden signed the 21st Century Peace Through Strength Act (Act) into law. The Act, which is part of a broader law providing supplemental aid to Israel, Taiwan and Ukraine, contains several...more
6/3/2024
/ Anti-Money Laundering ,
Biden Administration ,
CFIUS ,
Economic Sanctions ,
EU ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Statute of Limitations ,
TWEA ,
UK
The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has recently taken steps to expand the reach of the Bank Secrecy Act (BSA) and related customer identification regulations. These steps build on...more
5/30/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Beneficial Owner ,
CFIUS ,
Customer Identification Program (CIP) ,
Financial Institutions ,
FinCEN ,
Policies and Procedures ,
Proposed Rules ,
Regulatory Requirements ,
Securities and Exchange Commission (SEC)
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
5/3/2024
/ Asset Freeze ,
Asset Seizure ,
Economic Sanctions ,
Export Controls ,
International Trade ,
Investors ,
Joe Biden ,
Legislative Agendas ,
National Security ,
New Legislation ,
Russia ,
Ukraine
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
3/26/2024
/ Blocked Person ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
International Trade ,
National Security ,
New Rules ,
Office of Foreign Assets Control (OFAC) ,
Regulatory Agenda ,
Regulatory Reform ,
SDN List
The Corporate Transparency Act and its implementing regulations (together CTA) came into effect on January 1, 2024, requiring entities within its scope to disclose information, including about their beneficial owners, to the...more
2/2/2024
/ Beneficial Owner ,
Business Entities ,
Business Ownership ,
Corporate Governance ,
Corporate Transparency Act ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
New York ,
Popular ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements