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The U.S. and EU Coordinate Sanctions Related to Navalny Poisoning and Sentencing: Biden Administration’s First Sanctions Against...

Executive Summary - On March 2, 2021, the Biden Administration, in a coordinated announcement by the U.S. Departments of Treasury, State, and Commerce, tightened export restrictions against Russia and imposed sanctions and...more

New Export Controls: Emerging Technologies

The U.S. Department of Commerce, Bureau of Industry and Security (“BIS”) on October 5, 2020, published a final rule implementing new export controls on six categories of emerging technology. In doing so, the U.S. government...more

CFIUS Finalizes Changes to Mandatory Declaration Regulations

President Trump signed into law the Foreign Investment Risk Review Modernization Act of 2018 (“FIRRMA”) on August 13, 2018. FIRRMA made several substantial changes to the CFIUS process and expanded the scope of the...more

Potential Expansion of U.S. Export Controls: “Foundational” Technologies, Commodities and Software

The Department of Commerce, Bureau of Industry and Security (“BIS”), published an advance notice of proposed rulemaking (“the Notice”), on August 27, 2020, announcing the initiation of its review of foundational technologies...more

Department of Commerce Regulatory Changes: Eliminating Export Exemptions and Increasing Compliance Obligations to Gain Insight...

On April 28, 2020, the Commerce Department’s Bureau of Industry and Security (“BIS”) published two final rules and one proposed rule targeting national security controlled exports and reexports to China, Russia, and...more

International Trade Roundup: PPE Export Exemptions, Import Duty Postponement and Border Closures

Key Takeaways - The Federal Emergency Management Agency (“FEMA”) issued a regulation allowing companies to export personal protective equipment (“PPE”) in 10 defined circumstances discussed below. - U.S. Customs and...more

COVID-19: International Trade Navigation

The outbreak of COVID-19 is impacting international trade as global markets deal with uncertain supply and companies and governments work to ensure personal safety while developing contingency plans for handling the virus. In...more

Cloud Solutions Allowed for Encrypted, Unclassified Defense Data

The State Department’s Directorate of Defense Trade Controls (“DDTC”) published an interim final rule on December 26, 2019, bringing the International Traffic in Arms Regulations’ (“ITAR”) treatment of encrypted electronic...more

DOJ Revised Policy on Voluntary Self-Disclosures of Sanctions and Export Violations

On December 13, 2019, the U.S. Department of Justice (“DOJ”) issued a new policy for companies that voluntarily disclose potential criminal violations of U.S. sanctions and export control laws to the DOJ’s National Security...more

New Government Regulation of Emerging Technology

The U.S. Government has instituted a major new initiative to regulate emerging technology, potentially including artificial intelligence, biotechnology, robotics, data analytics and many other types of emerging technology,...more

End of the Road: U.S. Sanctions on Iran Come Back Into Effect

On November 5, 2018, applicable wind-down periods for certain transactions with Iran ended and the second and final set of U.S. secondary sanctions that had been lifted pursuant to the Iran nuclear deal – the Joint...more

USMCA Scales Back on Investor-State Arbitration but Preserves Trade Dispute Resolution in North America

The United States, Canada and Mexico on September 30 announced the framework for a new, revised trade agreement to replace NAFTA, called the United States-Mexico-Canada Agreement (the “USMCA”)....more

U.S. Moves Cautiously to Impose Mandated Sanctions Against Russia, While Congress Mulls Further Measures

On August 24, 2018, the U.S. Department of State announced a new but limited export licensing policy for defense and national security-sensitive goods and technology to Russia, effective August 27, 2018. The export licensing...more

Trade War Escalates with China Tariffs

The United States put into effect new tariffs on July 6, 2018, on roughly US$34 billion in Chinese products. In response, the Chinese government instituted retaliatory tariffs on a comparable quantity of U.S. products....more

More Tariffs: New Tariffs Target Chinese Imports

The U.S. Trade Representative (USTR) announced 25% tariffs on Chinese goods on June 15, targeting industrial goods that amount to roughly US$34 billion in annual exports to the United States, with a review underway for an...more

OFAC Issues Important Updates and Clarifications to Russia Sanctions

The Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury issued updated general licenses and related guidance in connection with sanctions imposed in April on certain Russian individuals and entities...more

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