On August 9, 2023, after more than a year of deliberations, the Biden administration finally released an executive order (the Order) directing the Department of the Treasury (Treasury) to create a new regulatory program to...more
8/11/2023
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Biden Administration ,
CFIUS ,
China ,
Cross-Border Transactions ,
Cybersecurity ,
Executive Orders ,
Foreign Direct Investment ,
Foreign Investment ,
National Security ,
Technology Sector
On March 11, 2022, President Joe Biden signed Executive Order 14068 (E.O. 14068) imposing new restrictions on imports and exports with respect to Russia as well as on the supply of U.S. dollar-denominated banknotes to the...more
3/22/2022
/ Bank Notes ,
Banks ,
Biden Administration ,
Economic Sanctions ,
Executive Orders ,
Export Controls ,
Exports ,
Financial Institutions ,
Luxury Goods ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Ukraine
On March 8, 2022, President Joe Biden issued Executive Order (E.O.) 14066, which bans the import of Russian oil, gas and other energy products into the United States and imposes sweeping prohibitions on new U.S. investment in...more
As the digital asset sector has exploded in recent years, there has been growing frustration in the U.S. at the lack of clarity on the application of existing laws to this new ecosystem and a perceived lack of coordination...more
On June 3, 2021, President Joe Biden issued Executive Order 14032 (EO 14032) amending and, in effect, recasting Executive Order 13959 of November 12, 2020 (EO 13959), which restricted U.S. persons from purchasing and selling...more
On April 15, 2021, President Joe Biden issued Executive Order 14024, titled the “Executive Order on Blocking Property With Respect to Specified Harmful Foreign Activities of the Government of the Russian Federation,” which...more
In response to the February 1, 2021, military coup in Burma (Myanmar), on February 10, 2021, President Joe Biden issued Executive Order 14014 (EO 14014), “Executive Order on Blocking Property With Respect to the Situation in...more
On November 12, 2020, President Trump signed Executive Order 13959 prohibiting U.S. persons from engaging in any transaction in publicly traded securities in “Communist Chinese military companies” (CCMCs), effective January...more
11/18/2020
/ Biden Administration ,
China ,
Department of Defense (DOD) ,
Executive Orders ,
Foreign Relations ,
National Security ,
NDAA ,
Office of Foreign Assets Control (OFAC) ,
Publicly-Traded Companies ,
Securities Transactions ,
Trump Administration
On August 31, 2020, the Office of Information and Regulatory Affairs (OIRA), within the Office of Management and Budget (OMB), issued a memorandum to all executive departments and agencies on reforming regulatory enforcement...more
10/14/2020
/ Administrative Proceedings ,
Best Practices ,
Burden of Proof ,
CFTC ,
Civil Liability ,
Civil Monetary Penalty ,
Criminal Penalties ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Executive Orders ,
FinCEN ,
Office of Foreign Assets Control (OFAC) ,
OMB ,
Publicly-Traded Companies ,
Regulatory Oversight ,
Securities and Exchange Commission (SEC) ,
Standard of Review
In light of Turkey’s military intervention in northeast Syria, President Donald Trump issued, on October 14, 2019, Executive Order 13894 (EO 13894), “Blocking Property and Suspending Entry of Certain Persons Contributing to...more
10/21/2019
/ Blocked Person ,
Economic Sanctions ,
Executive Orders ,
Foreign Financial Institutions (FFI) ,
General Licenses ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Secondary Sanctions ,
Steel Industry ,
Syria ,
Tariffs ,
Trump Administration ,
Turkey
In 2018, the United States continued to expand its sanctions programs and increase enforcement. While President Donald Trump’s decision to re-impose nuclear-related sanctions on Iran has perhaps drawn the most attention, key...more
1/23/2019
/ Blocked Entities ,
Blocked Person ,
Cryptocurrency ,
Cuba ,
Economic Sanctions ,
Executive Orders ,
Foreign Policy ,
General Licenses ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Nicaragua ,
Nuclear Power ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanction Violations ,
SDN List ,
Secondary Sanctions ,
Trump Administration ,
Venezuela ,
Withdrawal
On November 5, 2018, the United States reimposed all remaining nuclear-related sanctions against Iran that it had previously lifted in connection with its implementation of the Joint Comprehensive Plan of Action (JCPOA) in...more
11/13/2018
/ Cross-Border Transactions ,
Economic Sanctions ,
Executive Orders ,
Financial Institutions ,
Iran ,
Iran Sanctions ,
ITSR ,
Joint Comprehensive Plan of Action (JCPOA) ,
Nuclear Power ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
SDN List ,
Secondary Sanctions ,
Trump Administration ,
Winding Down ,
Withdrawal
On November 1, 2018, President Donald Trump issued Executive Order 13850 (E.O. 13850), which broadly targets corrupt practices in Venezuela and builds on several recent rounds of U.S. sanctions against the Venezuelan...more
11/9/2018
/ Corruption ,
Defense Sector ,
Economic Sanctions ,
Energy Sector ,
Engineering ,
Executive Orders ,
Government Officials ,
Mining ,
Rare Earth Metals ,
State-Owned Enterprises ,
Trump Administration ,
Venezuela
The U.S. government recently took several actions involving the Venezuela- and Russia-related sanctions. On May 21, 2018, following the re-election of President Nicolás Maduro, President Donald Trump issued an executive order...more
On April 6, 2018, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced sanctions against seven Russian oligarchs, 12 companies owned or controlled by these oligarchs, 17 senior Russian government...more
4/13/2018
/ Blocked Person ,
CAATSA ,
Economic Sanctions ,
Executive Orders ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Reporting Requirements ,
Russia ,
SDN List ,
Secondary Sanctions ,
Trump Administration ,
U.S. Treasury ,
Ukraine
On October 6, 2017, President Donald Trump and the U.S. Department of State announced the revocation of economic sanctions on Sudan, following the temporary lifting of sanctions on January 17, 2017. The announcement concluded...more
On August 25, 2017, the U.S. government dramatically increased sanctions on the government of Venezuela. Unlike the Venezuela-related sanctions already in effect, which are list-based and to date have targeted only specific...more
8/31/2017
/ Blocked Person ,
Bonds ,
Capital Markets ,
Citgo ,
Debt-Equity ,
Dividends ,
Economic Sanctions ,
Executive Orders ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Securities Transactions ,
State-Owned Enterprises ,
Trump Administration ,
Venezuela
On August 2, 2017, President Donald Trump signed into law the Countering America’s Adversaries Through Sanctions Act (the Act), which significantly expands U.S. sanctions against Russia while enacting modest new sanctions on...more
8/7/2017
/ Anti-Corruption ,
Anti-Terrorism Financing ,
Arms Embargo ,
Congressional Override ,
Constitutional Challenges ,
Cyber Sanctions ,
Economic Sanctions ,
Executive Orders ,
Exports ,
Foreign Financial Institutions (FFI) ,
Foreign Relations ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
North Korea ,
Oil & Gas ,
Pipelines ,
Privatization ,
Russia ,
SDN List ,
SSI List ,
State-Owned Enterprises ,
Syria ,
Trump Administration
After nearly two decades, the United States has formally ended economic sanctions on Burma (Myanmar). Citing substantial efforts undertaken to promote democracy, President Barack Obama issued an executive order, on October 7,...more
10/15/2016
/ Anti-Money Laundering ,
Barack Obama ,
Burma ,
Economic Sanctions ,
Executive Orders ,
Financial Transactions ,
FinCEN ,
Foreign Investment ,
Imports ,
Office of Foreign Assets Control (OFAC) ,
Patriot Act ,
SDN List ,
US Department of State
While economic sanctions against Iran, Russia and Cuba have dominated the headlines over the past year, sanctions remain a dynamic component of U.S. foreign policy on other fronts. In 2015, President Barack Obama issued three...more
1/23/2016
/ Burundi ,
Cross-Border Transactions ,
Cuba ,
Cyber Attacks ,
Economic Sanctions ,
Executive Orders ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
Human Rights ,
Iran Sanctions ,
Obama Administration ,
Russia ,
Venezuela