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Trump NSPM Proposes Changes to CFIUS Process and Outbound Investment Rules

On Friday, February 21, 2025, President Trump issued a National Security Presidential Memorandum (“NSPM”) titled “America First Investment Policy” which directed multiple federal agencies to take action to further restrict...more

New Executive Order Directs DOJ to Pause FCPA Enforcement

On February 10, 2025, President Trump issued an executive order that instructed DOJ to pause all action related to enforcement of the Foreign Corrupt Practices Act (FCPA). Enacted in 1977, the FCPA features anti-bribery...more

Executive Order Imposes New Russia Sanctions for Foreign Financial Institutions and Prohibits Additional Russian Imports

On December 22, 2023, President Biden issued Executive Order 14114, which amended previous Executive Orders in order to authorize the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) to impose additional...more

Biden Administration Issues Executive Order to Restrict U.S. Investment in Chinese Technology Sectors

Last week, President Biden issued an Executive Order outlining the long-anticipated proposed restrictions on outbound U.S. investments in entities located in China or otherwise subject to China’s jurisdiction. The Executive...more

OFAC Issues New Sanctions Prohibiting Certain Accounting, Auditing, Corporate Formation and Management Services to Persons in...

On May 8, 2022 the U.S. Department of the Treasury’s (“Treasury”) Office of Foreign Assets Control (“OFAC”) further escalated U.S. sanctions against the Russian Federation (“Russia”) by issuing two Determinations, adding new...more

U.S. Imposes More Russian Sanctions and Export Controls on Consumer Items and Luxury Goods, U.S. Dollar-Denominated Banknote...

On Friday, March 11, 2022, the White House issued Executive Order (“EO”) 14068 announcing more sanctions and export controls against the Russian Federation (“Russia”). Concurrent with that announcement, the U.S....more

President Biden Issues Executive Order Banning U.S. Imports of Russian Origin Oil, Gas, and Coal

On March 8, 2022, President Biden issued Executive Order 14066 which prohibits the following actions: The importation into the United States of any “crude oil; petroleum; petroleum fuels, oils, and products of their...more

U.S. Imposes More Sanctions and Export Controls against Russia and Belarus

On February 24, 2022, the U.S. imposed sweeping sanctions and export controls actions in response to the Russian Federation’s (“Russia”) “war of choice” against Ukraine. ...more

New Executive Order Imposes Sanctions on Donetsk and Luhansk People’s Republics in Ukraine

On February 21, 2022, U.S. President Joseph R. Biden Jr. issued an Executive Order (the “Ukraine Order”) in response to action taken earlier in the day by Russian Federation President Vladimir Putin to recognize the Donetsk...more

OFAC Sanctions Four Ukrainian Officials for Acting on Russia’s Behalf; Additional Russia Sanctions Could Follow

As tensions run high between Washington and Moscow over a possibly imminent Russian invasion of Ukraine, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated today four (4) current and...more

New Executive Order Authorizes Imposition Of Additional Sanctions On The Government Of Belarus And Certain Sectors Of The...

On August 9, 2021, President Biden issued Executive Order 14038 (the “EO”) which expanded the scope of the national emergency previously declared in EO 13405 of June 16, 2006. The EO imposes additional sanctions in response...more

Biden Administration Imposes New Russia Sanctions And Establishes Framework For Future Expansion Of Russian Sanctions Regime

Recently, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) sanctioned various individuals and entities connected to Russia’s technology sector and also expanded sanctions against dealings in Russian...more

U.S. Imposes Targeted Sanctions And Export Restrictions On Burma In Response To Military Coup

On February 1, 2021, the military of Burma (Myanmar) in an unanticipated coup d’état installed General Min Aung Hlaing as leader and detained the country’s top elected leaders, including the President and Prime Minister. In...more

OFAC Implements Hong Kong-Related Sanctions Regulations Pursuant To E.O. 13936

The U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) published regulations in the Federal Register on January 15, 2021 to implement Executive Order 13936 (“E.O. 13936”), titled “The President’s...more

Commerce Publishes Interim Final Rule Addressing “Foreign Adversaries” In ICTS Supply Chain

On January 19, 2021, the U.S. Department of Commerce (Commerce) published a long-awaited interim final rule to address the use of goods or services sourced from “foreign adversaries” in the U.S. supply chain for information...more

TikTok Legal Drama Continues To Unfold Across Multiple Courtrooms And Federal Agencies

The Trump Administration has encountered further setbacks in its efforts to prevent Chinese company ByteDance Ltd. (“ByteDance”) from providing its popular social media app TikTok in the U.S. For background:.....more

Executive Order Prohibits U.S. Persons From Investing In “Communist Chinese Military Companies”

President Trump issued an Executive Order (“E.O.”) on November 12, 2020 titled “Addressing the Threat from Securities Investments that Finance Communist Chinese Military Companies.” The E.O., which will be published in the...more

White House Rescinds Sudan’s State Sponsor Of Terrorism Designation, Continues National Emergency

On November 2, 2020, the White House released a notice continuing the national emergency with respect to Sudan declared in Executive Order 13067 of 1997. Secretary of State Mike Pompeo issued a press statement clarifying...more

U.S. Moves To Block Conventional Arms Sales To Iran

President Trump issued an Executive Order on September 21, 2020 which, effective immediately, imposes secondary sanctions on the transfer and sale of certain conventional arms shipments and the supply of related services to...more

U.S. Scheduled Bans On TikTok And WeChat Apps Delayed

China-based smartphone apps, TikTok and WeChat, have each received a reprieve from the respective bans, which were originally ordered by President Trump on August 6, 2020 against both parties and were scheduled to take effect...more

DOE Turns To Industry For Input On Bulk-Power Foreign Adversary Rules

The Department of Energy (DOE) has solicited the electric industry to request information to assist the DOE in drafting forthcoming rules that will prohibit the U.S. bulk-power electric system from using equipment sourced...more

New Executive Order Prohibits Use Of Equipment Produced By Foreign Adversaries In Bulk-Power Systems

On Friday, May 1, 2020, President Trump issued a new Executive Order (the Bulk-Power Order) to prohibit transactions within the U.S. for the acquisition or installation of certain “bulk-power system electric equipment” which...more

Trump Administration Expands Iran Sanctions To New Sectors In Recent Executive Order

In a January 14th Executive Order, President Trump expanded sanctions on Iran after a ballistic missile attack on two American military bases in Iraq. Executive Order 13902 expands secondary sanctions on Iran to capture...more

President Trump Imposes Sanctions Against Turkey For Its Syria Offensive

On October 14, 2019, President Trump announced via Twitter his intention to authorize sanctions against Turkey and “any persons contributing to Turkey’s destabilizing actions in northeast Syria.” The announcement followed...more

President Trump Declares National Emergency Over Technology Threats

On May 15, 2019, President Trump issued Executive Order 13873 (“E.O. 13873”) and declared a national emergency in response to increasing actions by “foreign adversaries” to create and exploit “vulnerabilities in information...more

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