On June 21, 2024, the US Department of the Treasury (Treasury) released proposed new federal regulations (Proposed Rules) that, if implemented, would prohibit or require notification of a broad range of outbound investment...more
7/9/2024
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
China ,
Covered Person ,
Covered Transactions ,
Data Privacy ,
Data Security ,
Foreign Persons ,
Information Technology ,
Investment ,
National Security ,
Popular ,
Prohibited Transactions ,
Proposed Regulation ,
Regulatory Agenda ,
U.S. Treasury
The measure also harmonizes Russia sanctions rules with allies, and intensifies penalties against Iran -
The National Security Act, 2024 (Pub. L No 118-50) was enacted on April 24, 2024. In addition to the Act’s provisions...more
4/29/2024
/ China ,
EU ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Direct Product Rule ,
Iran ,
National Security ,
Regulatory Agenda ,
Regulatory Reform ,
Russia ,
Sanction Violations ,
Statute of Limitations ,
Trade Policy ,
UK
Contemporaneous with the European Union’s adoption of its 13th package of Russia sanctions, on February 23, 2024, the United States imposed sanctions against nearly 500 targets in continued response to Russia’s aggression...more
2/27/2024
/ Biden Administration ,
Defense Sector ,
Economic Sanctions ,
Executive Orders ,
Federal Procurement Systems ,
Financial Institutions ,
Financial Transactions ,
FinTech ,
Foreign Policy ,
General Licenses ,
Military Conflict ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Payment Systems ,
Russia ,
Russian Military Procurement ,
SDN List ,
Ukraine ,
US State Departments
In response to an agreement reached on Tuesday between President Nicolás Maduro’s representatives and the Venezuelan political opposition about a road map for the 2024 Venezuelan presidential election, on October 18, the...more
After months of deliberation, on August 9, 2023, President Biden issued the executive order “Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern” (Order), with...more
On July 31, 2023, the US Department of the Treasury-led Committee on Foreign Investment in the United States (CFIUS or the Committee) released its annual report for calendar year 2022 (2022 Report), which provides insight...more
On May 19, 2023, the Biden Administration along with leaders of the Group of Seven (G7), unveiled a new package of sanctions. The G7 leaders released a joint statement reaffirming their commitment to offer “the financial,...more
6/6/2023
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Defense Sector ,
Economic Sanctions ,
Energy Sector ,
Entity List ,
Evasion ,
Executive Orders ,
Export Controls ,
Foreign Policy ,
G7 ,
General Licenses ,
Military Conflict ,
Office of Foreign Assets Control (OFAC) ,
Prohibited Transactions ,
Russia ,
SDN List ,
Third-Party ,
U.S. Commerce Department ,
Ukraine
On April 19, 2023, the US Department of Commerce Bureau of Industry and Security (BIS) entered into a settlement agreement wherein Seagate Technology LLC and Seagate Singapore International Headquarters Pte. Ltd....more
4/27/2023
/ Bureau of Industry and Security (BIS) ,
Civil Monetary Penalty ,
Enforcement Actions ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Huawei ,
Sanction Violations ,
Settlement Agreements ,
U.S. Commerce Department
In recognition of the one-year anniversary of Russia’s invasion of Ukraine, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) and US Department of Commerce’s Bureau of Industry and Security (BIS)...more
3/6/2023
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Embargo ,
EU ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Financial Transactions ,
Foreign Policy ,
Foreign Relations ,
Foreign Trade Regulations ,
General Licenses ,
Military Conflict ,
Office of Foreign Assets Control (OFAC) ,
Oil Prices ,
Petroleum ,
Russia ,
SDN List ,
Switzerland ,
Ukraine
On February 5, 2023, the G7 announced that the “price cap” on western-backed seaborne trades of Russian-origin petroleum products to third countries would be set at $45 per barrel ($45/bbl) for Discount to Crude petroleum...more
2/27/2023
/ EU ,
Exports ,
G7 ,
Goods or Services ,
Imports ,
Maritime Transport ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Oil Prices ,
Petroleum ,
Russia ,
Sanction Violations ,
Shipping ,
Suppliers ,
Supply Contracts ,
Ukraine
Amid the 4,000 pages of provisions in the recently enacted Fiscal Year 2023 National Defense Authorization Act (NDAA) are prohibitions and associated requirements relating to the federal procurement of certain Chinese...more
1/3/2023
/ China ,
Covered Entities ,
Defense Sector ,
Department of Defense (DOD) ,
Federal Acquisition Regulations (FAR) ,
Federal Contractors ,
Information Technology ,
National Security ,
NDAA ,
Procurement Guidelines ,
Semiconductors ,
Telecommunications
Oil price cap -
The oil price cap has been co-ordinated by the G7 in order to make EU, UK and US services (including (re)insurance) available to third country importers and exporters as long as the price paid for...more
12/12/2022
/ Asset Freeze ,
Belarus ,
Belarus Sanctions ,
Biden Administration ,
Crude Oil ,
Economic Sanctions ,
EU ,
Export Controls ,
Exports ,
G7 ,
General Licenses ,
Imports ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Oil Prices ,
Russia ,
SDN List ,
Switzerland ,
Third Country Entities (TCEs) ,
UK ,
Ukraine
The Office of Foreign Assets Control (OFAC) of the US Treasury Department has issued its eagerly awaited guidance on the mechanisms of its “maritime services” policy and “price cap exception” for the global transport of...more
Recently, the US Department of Commerce Bureau of Industry and Security (BIS) issued an interim final rule imposing additional export controls on certain advanced computing and semiconductor manufacturing items and for...more
11/4/2022
/ Bureau of Industry and Security (BIS) ,
China ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Interim Final Rules (IFR) ,
Manufacturers ,
Military End Use ,
National Security ,
Technology Sector ,
U.S. Commerce Department
Recently, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) has taken additional actions against Russia in response to its continued invasion of Ukraine. Specifically, OFAC:
..Issued guidance...more
10/31/2022
/ Asset Freeze ,
Belarus ,
Blocked Entities ,
Blocked Person ,
Economic Sanctions ,
EU ,
Export Controls ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Switzerland ,
Trade Restrictions ,
UK ,
Ukraine
Recently, the Biden Administration adopted additional sanctions in response to Russia’s attempts to annex parts of sovereign Ukrainian territory, including the designation of 14 persons in Russia’s military industrial...more
10/13/2022
/ Belarus ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Military Conflict ,
Military End Use ,
New Guidance ,
Russia ,
Third Country Entities (TCEs) ,
U.S. Commerce Department ,
Ukraine
Over the past few weeks, the Office of Foreign Assets Control (OFAC) of the US Department of the Treasury ramped up sanctions pressure against Russia with the announcement of a new ban on certain services in seaborne Russian...more
9/23/2022
/ Asset Freeze ,
Belarus ,
Belarus Sanctions ,
Blocked Entities ,
Blocked Person ,
Economic Sanctions ,
Export Controls ,
General Licenses ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Russia ,
Ukraine
As a follow up to our alert of September 7th regarding the G7 proposal to implement a price cap with respect to seaborne Russian-origin crude oil and petroleum products, the Office of Foreign Assets Control (OFAC)...more
9/13/2022
/ Crude Oil ,
Economic Sanctions ,
Embargo ,
EU ,
Maritime Transport ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Oil Prices ,
Recordkeeping Requirements ,
Russia ,
Safe Harbors ,
Shipping
On September 2, 2022, the G7 Finance Ministers issued a statement confirming their intention to implement a price cap with respect to Russian-origin crude oil and petroleum products in response to Russia’s continued invasion...more
9/8/2022
/ Crude Oil ,
Economic Sanctions ,
EU ,
G7 ,
Importers ,
Imports ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Pipelines ,
Pricing ,
Russia ,
Ukraine
Over the past few weeks, the US Department of Treasury Office of Foreign Assets Control (OFAC) took various actions in response to Russia’s continued invasion in Ukraine:
..updated the Specially Designated Nationals and...more
8/17/2022
/ Asset Freeze ,
Belarus ,
Belarus Sanctions ,
Blocked Entities ,
Blocked Person ,
Economic Sanctions ,
Entity List ,
Export Controls ,
General Licenses ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Russia ,
SDN List ,
Ukraine
Over the past few weeks, the US Department of the Treasury Office of Foreign Assets Control (OFAC) took additional actions in response to Russia’s continued invasion of Ukraine:
..Removed Kazakh subsidiary of Alfa Bank,...more
The US continues to ramp up sanctions pressure on Russia, now emphasizing Russian efforts to evade US export controls and obligations of financial institutions to police Russian efforts at sanctions and export controls...more
7/6/2022
/ Asset Freeze ,
Belarus ,
Belarus Sanctions ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Entity List ,
EU ,
Export Controls ,
Exports ,
FinCEN ,
Foreign Relations ,
General Licenses ,
Military Conflict ,
Oil & Gas ,
Russia ,
Switzerland ,
Trade Restrictions ,
UK ,
Ukraine
The Uyghur Forced Labor Prevention Act (the UFLPA) came into effect last week, and US Customs and Border Protection (CBP) and US Department of Homeland Security (DHS) have released guidance for importers for demonstrating...more
7/5/2022
/ Biden Administration ,
China ,
Compliance ,
Customs and Border Protection ,
Department of Homeland Security (DHS) ,
Effective Date ,
Entity List ,
Forced Labor ,
Importers ,
Imports ,
New Guidance ,
Rebuttable Presumptions ,
Supply Chain ,
Uyghur Forced Labor Prevention Act (UFLPA)
Following the invasion of Ukraine by Russia, the UK, EU and US have all responded by announcing significant sanctions in respect of Russia and Belarus.
This briefing summarises the key developments since 25 April 2022 and...more
Asset Freezes -
On 13 and 14 April 2022, the UK imposed asset freezes with respect to 208 individuals. This included alleged separatists, oligarchs, close associates and employees of oligarchs and individuals who have...more