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
2/26/2025
/ Artificial Intelligence ,
CFIUS ,
China ,
Defense Production Act ,
Executive Orders ,
Export Controls ,
Foreign Investment ,
Foreign Policy ,
National Security ,
Presidential Memorandum ,
Semiconductors ,
Trump Administration
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
2/19/2025
/ Anti-Corruption ,
Compliance ,
Corporate Governance ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Executive Orders ,
Federal Contractors ,
Foreign Corrupt Practices Act (FCPA) ,
Securities and Exchange Commission (SEC) ,
Trump Administration
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
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
8/17/2023
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Artificial Intelligence ,
Biden Administration ,
China ,
Electronics ,
Executive Orders ,
Foreign Investment ,
ITAR ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Outbound Transactions ,
Semiconductors ,
Technology Sector ,
U.S. Treasury
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
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
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
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
3/8/2022
/ Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
European Central Bank ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
General Licenses ,
Joe Biden ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
SWIFT ,
U.S. Commerce Department ,
U.S. Treasury ,
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
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
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
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
4/21/2021
/ Biden Administration ,
Cyber Attacks ,
Cyber Crimes ,
Defense Sector ,
Election Interference ,
Executive Orders ,
Export Controls ,
Foreign Policy ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
Sanctions ,
SDN List ,
Sovereign Debt ,
State-Owned Enterprises ,
Technology Sector ,
U.S. Treasury
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
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
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
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
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
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
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
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
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
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
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
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
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