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Export Control Shake-Up: Navigating the Expanded Export Restrictions

On July 29, 2024, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) proposed a series of transformative new rules aimed at tightening controls related to military, intelligence, and security activities...more

China Semiconductor Export Regulations, Episode V – Updates and Corrections to the Advanced Computing and Semiconductor...

On March 29, 2024, BIS issued an interim final rule (IFR) updating and correcting its advanced computing and semiconductor regulations published in October 2023 (which we discuss here in Episode III). This marks the third...more

Department of Commerce Initiates Investigation into Chinese-Made “Connected Vehicles”: Potential Prohibitions on Certain...

On February 29, 2024, the Biden administration issued a statement addressing the national security risks to the U.S. auto industry directing the Department of Commerce to conduct an investigation into Chinese made “connected...more

Guidance to Foreign Companies on Export Controls and Sanctions: Departments of Commerce, Treasury, and Justice Issue Tri-Seal...

On Wednesday, March 6, 2024, the Department of Commerce, Department of the Treasury and Department of Justice issued another Tri-seal Compliance Note, focusing this time on the obligations of foreign based persons complying...more

Sanctions Enforcement in the Cryptocurrency Industry Continues to be a Focus

On December 13, 2023, CoinList Markets LLC (“CoinList”) agreed to pay $1,207,830 pursuant to a settlement agreement with the Office of Foreign Assets Controls (“OFAC”) in connection with allegations that the San Francisco...more

Binance’s Paper Compliance Program Crumples Under OFAC Scrutiny in Largest OFAC Settlement in History

On November 21, 2023, the U.S. Office of Foreign Assets Control (OFAC) announced its largest settlement in history with the virtual currency exchange Binance. This almost-billion dollar settlement is a part of a larger...more

China Semiconductor Export Regulations, Episode III – What a Difference a Year Makes

On Tuesday, October 17, 2023, the U.S. Bureau of Industry and Security (BIS) released a package of three rules (the 2023 Rules) targeting the Chinese semiconductor industry. The rules update the substantial semiconductor...more

New Outbound Investment Restrictions Affect China, Semiconductors, Artificial Intelligence, and Quantum Computing

On August 9, 2023, President Biden issued an Executive Order (E.O.) ordering the issuance of outbound investment restrictions. This E.O. comes after nearly a year of anticipation (as we have documented on several occasions...more

Technology Protection is a Core National Security Priority: BIS Strengthens Its Policy on Disclosures

Recently, the Department of Commerce issued a memo, emphasizing that “technology protection is a core national security priority” and how companies that choose not to disclose significant violations of export regulations may...more

OFAC Finds Digital Assets Trading Platform in Violation of Sanctions

On March 31, 2023, the Office of Foreign Assets Control (OFAC) announced a $72,230.32 settlement agreement with Uphold HQ Inc. (Uphold), a global multi-asset digital trading platform, in connection with 152 apparent...more

“Sanctions Are The New FCPA”: DOJ Increases Focus on Sanctions and Export Control Enforcement

On March 2, 2023, Deputy Attorney General Lisa Monaco delivered remarks to the ABA’s National Institute on White Collar Crime. Unsurprisingly, her remarks focused heavily on inspiring a culture of compliance – including...more

Friday Development: New Sanctions and Export Controls to Address Russia’s Ongoing Aggression in Ukraine (Including the use of...

In response to Russia’s ongoing aggression in Ukraine, both the United States and the European Union have imposed additional sanctions and further restricted exports to Russia and Iran. These new controls span many...more

Will We Ring in the New Year with Outbound Investment Restrictions?

As we close out a wild year for international trade regulation, after hearing much talk about outbound investment review mechanisms, we may see a final dramatic change before the ball drops...more

OFAC Continues Focus on Virtual Currency Industry with Announced Settlement with Payward, Inc.

Yesterday, on November 28, 2022, the Office of Foreign Assets Control (OFAC) announced a $362,158.70 settlement agreement with Payward, Inc. (Kraken), an online virtual currency exchange, in connection with 826 apparent...more

Bribes, Bitcoin and Obstruction: DOJ Announces Charges Against Chinese Agents for Trying to Impede Investigation of Huawei

On Monday, October 24, 2022, the Department of Justice (DOJ) announced charges against two alleged Chinese intelligence officers for bribing and stealing documents to obstruct the criminal investigation of, reportedly, Huawei...more

OFAC Issues Sanctions Compliance Guidance for Instant Payment Systems

On September 30, 2022, the Office of Foreign Assets Control (OFAC) published compliance guidance for instant payment systems. The guide highlights the need for emerging payment technology companies to assess their sanctions...more

OFAC Announces Hefty Settlement with Virtual Currency Exchange / Hosted Wallet Services Provider

Settlement Agreement with Bittrex, Inc. Today, on October 11, 2022, the Office of Foreign Assets Control (OFAC) announced a $24,280,829.20 settlement agreement with Bittrex, Inc., an online virtual currency exchange and...more

Technology to Iran: OFAC Lifts Certain Iran Sanctions In Response to Protests in Iran

After Mahsa Amini was killed in the custody of “Gasht-e-Ershad” or Iran’s Guidance Patrol, commonly referred to as Iran’s morality police, following an arrest for placement of her hijab, protests have erupted throughout Iran...more

Commerce Department Adds Guardrails Against Stockpiling of Certain Solar Cells and Modules During Temporary Waiver of AD/CVD...

On September 16, 2022, the U.S. Commerce Department released its final rule regarding antidumping and countervailing duty (AD/CVD) circumvention inquiries on solar cells and modules from Cambodia, Malaysia, Thailand, and...more

DOJ Issues Report on Efforts to Combat Digital Asset Criminal Activity and Announces Designated Prosecutors to Support

On September 16, the United States Department of Justice (“DOJ”) released a report on the Role of Law Enforcement in Detecting, Investigating, and Prosecuting Criminal Activity Related to Digital Assets pursuant to President...more

First-Ever Executive Order on CFIUS Highlights Biden’s National Security Priorities

On September 15, President Biden signed the first-ever Executive Order (E.O.) on CFIUS – the Committee on Foreign Investment in the United States. While the E.O. does not substantively change CFIUS’s jurisdiction or the legal...more

Introduction of internet-related Russia trade sanctions in the UK

On April 29, 2022, the UK introduced new measures to prevent the provision of internet services to or for the benefit of designated persons. These measures apply to the whole territory of the UK and to conduct by UK persons...more

President Biden Suspends AD/CVD Duties on Solar Cells and Modules from Cambodia, Malaysia, Thailand, and Vietnam

On Monday, President Biden issued an Executive Order suspending the collection of anti-dumping and countervailing duties (AD/CVD) of certain solar cells and modules exported from Cambodia, Malaysia, Thailand, and Vietnam...more

The Crypto Enthusiast and The Regulator: What OFAC is, Could Be, and Should Be Doing to Regulate CryptoCurrencies

On May 6, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated a cryptocurrency mixer, Blender.io, as a Specially Designated National (SDN). That sanction follows a series of enforcements and...more

Novel Sanctions Against Business-Related Services Connected to Russia and Additional Export Restrictions

On Sunday, the Department of Treasury’s Office of Foreign Assets Control (OFAC) announced novel and sweeping sanctions on specific categories of services in order to cripple Russia’s wartime capabilities and sanctioned key...more

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