The COVID-19 pandemic has thrown us all into a crisis of uncertainty. How does one stop a global pandemic? How long will it take to bend the contagion curve? How should the business community respond, to both the public...more
Taking a break from reporting on COVID-19 legal developments, we turn for a moment to what is happening now on export control of autonomous vehicle technology.
The autonomous vehicle R&D sector is booming, largely in the...more
4/9/2020
/ Automotive Industry ,
Connected Cars ,
Cybersecurity ,
Department of Transportation (DOT) ,
Driverless Cars ,
Legislative Agendas ,
Motor Vehicles ,
NHTSA ,
Regulatory Oversight ,
Safety Standards ,
Technology Sector
Money laundering is no game. Yet, some games have been used for money laundering. That’s what prompted Valve to announce that it would end the online sales of loot box “keys” for its game Counter-Strike Global Offensive...more
On June 13, 2019, the Office of the United States Trade Representative ruled that bifacial solar modules are exempt from the Section 201 tariffs on solar cell and module imports. This exemption applies to articles imported on...more
On March 8, the U.S. government signaled regulatory changes that may create new opportunities for international collaboration on satellite development, global sales of satellite and launch equipment, and even sharing launch...more
3/20/2019
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Departments of Commerce ,
Export Controls ,
Foreign Policy ,
ITAR ,
National Security ,
Proposed Rules ,
Public Comment ,
Regulatory Agenda ,
Satellites ,
Technology Sector ,
US Department of State ,
US Munitions List
Happy new year everyone. The government is shut down, but there has already been a flurry of activity in 2019 on the economic sanctions and embargoes front. Here is a summary of where we stand on various sanctions regimes....more
1/16/2019
/ CAATSA ,
Economic Sanctions ,
Government Shutdown ,
Iran ,
Iran Sanctions ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Syria ,
Trump Administration ,
U.S. Treasury ,
Venezuela
• Emerging technology sectors are being reviewed now for new export controls that could take effect in 2019 (list below).
• You may submit comments on the criteria the U.S. government will use to determine what technologies...more
12/11/2018
/ Comment Period ,
Critical Infrastructure Sectors ,
Cross-Border Transactions ,
Emerging Technology Companies ,
Export Controls ,
Exports ,
Foreign Nationals ,
National Security ,
Proposed Rules ,
Public Comment ,
Technology Sector
On Sept. 4, 2018, the Federal Communications Commission issued a new rule requiring foreign media outlets to submit reports to the FCC disclosing their relationships with foreign principals. The notice was issued pursuant to...more
On September 4, 2018, the Federal Communications Commission issued a new rule requiring foreign media outlets to submit reports to the FCC disclosing their relationships with foreign principals. The notice was issued pursuant...more
9/21/2018
/ Broadcasting ,
Cable Television Providers ,
FCC ,
Foreign Agents ,
Foreign Governments ,
Media ,
Media Relations ,
NDAA ,
New Rules ,
Reporting Requirements ,
Telecommunications ,
Television Broadcast Stations ,
Video
A lot of us in the sanctions compliance world were wondering whether and when OFAC would issue official guidance on its application of sanctions in the digital currency world. On March 18, OFAC issued five FAQs related to...more
4/13/2018
/ Blocked Person ,
Cryptocurrency ,
Digital Currency ,
Economic Sanctions ,
Financial Instruments ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Regulatory Requirements ,
SDN List ,
Token Sales ,
Virtual Currency
Since the U.S. government determined that Russia interfered in the 2016 election, movement around Russia sanctions policy has been vigorous, if not unidirectional. Twice in 2016, the United States implemented sanctions...more
Since the U.S. Government determined that Russia interfered in the 2016 election, movement around Russia sanctions policy has been vigorous, if not unidirectional. In 2016, the United States implemented twice sanctions...more
2/9/2018
/ CAATSA ,
Defense Sector ,
Financial Institutions ,
Foreign Policy ,
Foreign Relations ,
National Security ,
Privatization ,
Russia ,
Sanctions ,
Secondary Sanctions ,
US Department of State
Russian President Vladmir Putin has directed his government to develop a state-backed cryptocurrency, according to a Financial Times report published on January 2nd. A Putin advisor says that the “Crypto-rouble” could be used...more
1/11/2018
/ Anonymity ,
Anti-Money Laundering ,
Bitcoin ,
Blockchain ,
Criminal Investigations ,
Cross-Border Transactions ,
Cryptocurrency ,
Digital Currency ,
Economic Sanctions ,
Enforcement Actions ,
Financial Institutions ,
Russia ,
Vladimir Putin
Remember how we talked about bipartisan legislation introduced in March 2017 (which seems like a million years ago) to investigate the Russian media outlet RT for spreading propaganda without registering as a foreign agent?...more
What does decertification mean?
For the time being, decertification is a solely U.S. issue. Under the Iran nuclear agreement (known as the Joint Comprehensive Plan of Action, or JCPOA), Iran agreed to limits on its nuclear...more
10/13/2017
/ Automotive Industry ,
Banking Sector ,
Energy Sector ,
Financial Transactions ,
Foreign Subsidiaries ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Nuclear Weapons ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Shipping ,
Sovereign Debt
According to reports published this week, the Trump Administration is preparing to release the results of its policy review on Cuba in the “coming weeks.” We don’t have a crystal ball (or a leaking insider). But we continue...more
6/1/2017
/ Airlines ,
Corporate Counsel ,
Cuba ,
Economic Sanctions ,
Embargo ,
Foreign Relations ,
Infrastructure ,
Popular ,
State Sponsors of Terrorism ,
Telecommunications ,
Travel Ban ,
Trump Administration ,
US Trade Policies
Late last week, Congressional intelligence committees reportedly received some information from the U.S. Financial Crimes Enforcement Network (FinCEN) related to investigations into Russia’s attack on the 2016 U.S....more
5/24/2017
/ Bank Secrecy Act ,
Banking Sector ,
BSA/AML ,
Donald Trump ,
Financial Institutions ,
FinCEN ,
Government Investigations ,
Money Laundering ,
Patriot Act ,
Political Campaigns ,
Presidential Elections ,
Russia ,
Suspicious Activity Reports (SARs)
Who would have thought that a little-known, 1930s-era law would suddenly become a household name? Not me. Not even as an attorney who counsels clients on compliance with the law and maintains a healthy (read: nerdy) interest...more
On January 10, 2017, Senate Republicans and Democrats introduced bi-partisan legislation called the “Countering Russian Hostilities Act of 2017,” which would impose broad sanctions on Russia. The Act would codify the...more
1/13/2017
/ Amended Legislation ,
Barack Obama ,
Bipartisan Agreement ,
Cyber Attacks ,
Cyber Sanctions ,
Economic Sanctions ,
Energy Sector ,
Executive Orders ,
Financial Institutions ,
Foreign Policy ,
Legislative Agendas ,
Office of Foreign Assets Control (OFAC) ,
Pending Legislation ,
Presidential Elections ,
Russia ,
Trump Administration ,
Vladimir Putin
After the announcement of Fidel Castro’s death on November 26, 2016, President Barack Obama sent a message to the Cuban people highlighting his administration’s efforts to improve relations between the United States and Cuba....more
With fewer than 100 days left in office, President Obama is not slowing down on his efforts to normalize relations between the United States and Cuba. Today, several changes to the Cuban Assets Control Regulations (CACR) and...more
10/18/2016
/ Aviation Industry ,
Barack Obama ,
Cuba ,
Cuban Assets Control Regulations (CACR) ,
Energy Sector ,
Export Administration Regulations (EAR) ,
Exports ,
Imports ,
Medical Research ,
Office of Foreign Assets Control (OFAC) ,
Travel
Last week, researchers at Citizen Lab uncovered sophisticated new spyware that allowed hackers to take complete control of anyone’s iPhone, turning the phone into a pocket-spy to intercept communications, track movements and...more
9/2/2016
/ Cyber Attacks ,
Cyber Espionage ,
Cyber Weapons ,
Export Controls ,
Foreign Governments ,
Hackers ,
iPhone ,
Israel ,
Malware ,
National Security ,
Pegasus ,
Spyware ,
Technology ,
The Wassenaar Arrangement
In late May, The Russian Federation issued its first sovereign bond since the Ukraine crisis in 2014. The sole organizer of the bond is VTB Capital, an arm of VTB Bank, Russia’s second largest financial institution. Both VTB...more
With more flights, relaxing regulations, a historic presidential trip to Cuba, and news of hospitality services expanding into Cuba, the pathway into Cuba for hotels and hospitality companies seems smooth. But businesses...more
After a twelve-year standoff that saw the United States and Europe ratchet up sanctions pressure on Iran, a diplomatic breakthrough has been reached. But robust trade between Iran and the West will not arise immediately,...more
7/19/2015
/ EU ,
Exports ,
IFCA ,
Iran ,
Iran Sanctions ,
Iran Threat Reduction and Syria Human Rights Act ,
Joint Comprehensive Plan of Action (JCPOA) ,
Manufacturers ,
NDAA ,
Non-US Entities ,
Nuclear Power ,
Nuclear Weapons