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UK Issues General Licence for Exports of Semiconductor and Other Emerging Technologies to Certain Countries

The UK government has issued an updated Open General Export Licence for the Export of Dual-Use items to EU Member States (which also previously covered exports to Iceland and the Channel Islands) (the “OGEL”) to allow export...more

UK Expands Export Controls to Semiconductor and Other Emerging Technologies

The UK has expanded its export controls regime to include a number of key emerging technologies, including in relation to semiconductors and quantum technology. These changes take effect on 1 April 2024, following which an...more

The European Economic Security Package

Building on the European Security Strategy of June 2023, the European Commission on January 24, 2024, adopted a package of five initiatives aiming to enhance the EU’s economic security. The package contains a far-reaching...more

M&A in 2023 and Trends for 2024

M&A activity in 2023 was subdued, as dealmakers grappled with geopolitical tensions, inflation, rising interest rates, and increasing regulatory scrutiny, against a backdrop of general economic uncertainty. Challenges in the...more

Sanctions Year in Review 2022 – Part II: Russia

As Russia’s war in Ukraine passes the one-year mark, and the battles on the ground move forward with escalating levels of ferocity, governments around the world continue to coordinate and respond with increasingly severe...more

Coalition Powers Impose Russian Oil Price Cap and Outline Implementation

As Russia’s war in Ukraine stretches into its tenth month, governments around the world continue to coordinate and respond with increasingly severe sanctions and export controls....more

Global Sanctions on Russia Escalate in Response to Russia’s Continued Bloody Invasion of Ukraine

As Russia’s bloody invasion of Ukraine nears the end of its second month, with regular reports of human rights violations, possible chemical weapons attacks, and head of state musings regarding whether this campaign amounts...more

U.S., EU, and UK Sanctions on Russia Escalate in Response to Russia’s Continued Invasion of Ukraine

As Russia’s brutal invasion of Ukraine stretches on into its second month, the United States, European Union, United Kingdom, and other global allies have continued to pour additional funding and arms into Ukraine while...more

United States, European Union, United Kingdom, and Other Nations Impose Sanctions in Response to Russia’s Brutal Invasion of...

After less than a week of a full-scale war between Russia and Ukraine, the post-Cold War global architecture appears irrevocably shattered, as Western nations line up to offer support and military and economic aid to Ukraine...more

DOJ Announces Resolution Of First-Ever Voluntary Self-Disclosure Related To Export Control And Sanctions Violations

On April 29, 2021, the U.S. Department of Justice’s National Security Division and the U.S. Attorney’s Office for the District of Massachusetts (collectively, “DOJ”) announced that DOJ entered into a precedent-setting...more

Defense Bill Aims Additional Sanctions At Turkey, Russia, And China

One of the widest-ranging bills of the U.S. Congress’s legislative year, the National Defense Authorization Act for Fiscal Year 2021 (NDAA), is nearing the finish line as both the House and Senate overwhelmingly approved the...more

Congress Pulls the Trigger on Russia’s Nord Stream 2 and TurkStream Pipeline Projects

As it nears the end of the calendar and legislative year, Congress is preparing to take long-awaited action to kill Russia’s Nord Stream 2 and TurkStream natural gas pipeline projects – months before Nord Stream 2’s...more

Congress Adds Potential U.S. Sanctions on Hong Kong to Escalating U.S.-China Tensions (Chinese Edition)

As another sign of the escalating tensions between the United States and China, in addition to the long-running trade war, China this week suspended visits to Hong Kong by the U.S. military and vowed to impose sanctions on a...more

Congress Adds Potential U.S. Sanctions on Hong Kong to Escalating U.S.-China Tensions

As another sign of the escalating tensions between the United States and China, in addition to the long-running trade war, China this week suspended visits to Hong Kong by the U.S. military and vowed to impose sanctions on a...more

Trump Reverses Course on Turkey

On October 23, 2019, the Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced it was removing three Turkish government ministers and two Turkish government ministries from its list of Specially Designated...more

Trump on Turkey: Sanctions on a NATO Ally Today, With Escalation or Removal Possible Tomorrow

On October 14, President Trump issued an Executive order (“E.O.”) imposing sanctions on Turkey in response to Turkey’s military offensive in northern Syria. New E.O. 13894 authorizes the U.S. Departments of State and the...more

Terrorism Sanctions Go Secondary

As part of the 18th anniversary of the September 11 attacks earlier this month, the Trump Administration effectively declared the old adage that “one person’s terrorist is another person’s freedom fighter” does not apply with...more

Back to the Future: Helms-Burton Versus the Blocking Statutes. Who Will Prevail?

Nearly a quarter century after its passage, the Cuban Liberty and Democratic Solidarity (Libertad) Act of 1996 – commonly known as Helms-Burton, after its sponsors – was expected to revive a significant number of old disputes...more

TGIF? No, CBW: U.S. Government Imposes Narrow Financing Restrictions and Other Sanctions on Russia

The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) has a well-earned reputation in the sanctions bar for ruining weekends. The agency responsible for implementing and enforcing U.S. economic sanctions has...more

OFAC’s Framework for Sanctions Compliance and its Impact on Recent Enforcement Cases

On May 2, 2019, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) published its first-ever Framework for OFAC Compliance Commitments (“Framework”), detailing the essential components of a sanctions...more

For Russia, Sanctions Are Coming

Back in February, we told you about the Defending American Security from Kremlin Aggression Act, or “DASKA,” a bipartisan effort to impose new sanctions on Russia. Interest in action against the Kremlin has only increased...more

The United States Imposes Additional Secondary Sanctions on Iran as Geopolitical Tensions Flare

With tensions rising in the Persian Gulf, and Iran on the brink of pulling out of portions of the Iran nuclear deal, President Trump issued new Executive Order 13871 last Wednesday, May 8, 2019, imposing sanctions on Iran’s...more

New EU Investment Screening Rules: 10 Key Things Dealmakers Need to Know

The EU has recently laid the ground to take a more active role in the screening of foreign direct investment (FDI). On April 10, 2019, the EU formally established a framework for foreign investment screening including a...more

INSTEX and Europe’s “Legitimate Trade” with Iran - Skepticism prevails as Instrument for Supporting Trade Exchanges (INSTEX) is...

Three weeks ago, France, Germany, and the United Kingdom (the “E3”) created INSTEX SAS (Instrument for Supporting Trade Exchanges, INSTEX), an entity designed to enhance business between the EU and Iran and to serve as a core...more

Iran Sanctions: Snap-Back, Part 2

Executive Summary - On November 5, 2018, the United States enacted the second of two powerful phases of the “snap-back” of Iran sanctions, re-imposing sanctions that were lifted by the United States in 2016 as a result of...more

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