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Commerce Department Publishes Interim Final ICTS "Foreign Adversary" Rules

Key Point: New rules will impact the use of equipment and digital services sourced from China and other “foreign adversaries” in a wide variety of transactions and activities that potentially pose a risk to U.S. national...more

Sudan’s Sponsor Of Terrorism Designation Officially Rescinded

The U.S. Department of State announced that Sudan’s designation as a “State Sponsor of Terrorism” has been officially rescinded effective December 14, 2020. In October, the President notified Congress that Sudan’s designation...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

Commerce Announces Revocation of License Exception CIV And New Rules To Further Restrict Transactions With China, Russia And...

On Tuesday, April 28, 2020, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued two new final rules scheduled to take effect on June 29, 2020, which will implement amendments to the U.S. Export...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

Trump Administration Grants 90-Day Extension Of TGL For Companies Doing Business With Huawei

The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) announced on Monday, November 18, 2019 the issuance of a new 90-day extension which will allow U.S. companies to continue doing business with Huawei...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

Trump Administration And BIS Announce Willingness To Issue Huawei Export Licenses; Criteria For Issuing Such Licenses Still...

As previously reported in our International Trade Insights blog, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) added Chinese telecommunications giant Huawei Technologies Co. Ltd. (“Huawei”) and...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

Huawei Targeted By Entity List Designation And Executive Order

On Wednesday, May 15, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) announced in a press release that it would add Huawei Technologies Co. Ltd. (“Huawei”) and additional Huawei affiliates to BIS’s...more

President Trump To End Sanctions Waivers For Iranian Oil

On April 21, 2019, the White House announced that President Trump has decided not to reissue the Iranian oil sanctions waivers, called “Significant Reduction Exceptions” (SREs) when they expire in early May. The White House...more

U.S. Reimposes Tough Sanctions On Iran; More Designations To Come

On November 5, 2018, the United States fully reimposed sanctions against Iran as part of its decision to withdraw from the Iran nuclear deal, also known as the Joint Comprehensive Plan of Action (“JCPOA”). President Trump...more

OFAC Extends Authorization Period For Licensed Transactions With Certain Russian SDNs

As previously covered on April 6, 2018, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) invoked authority provided under the Countering America’s Adversaries Through Sanctions Act (“CAATSA”) in...more

Trump Administration Issues New CAATSA Executive Order, Adds 33 Persons To LSP List And Sanctions Chinese Defense Buyer

On September 20, 2018, President Trump released a 16-page Executive Order which delegated various Presidential powers established under the Countering America’s Adversaries Through Sanctions Act (“CAATSA”) to both the U.S....more

United States Announces Re-Imposition Of First Round Of Nuclear Sanctions On Iran

President Trump signed a new Executive Order on August 6, 2018, titled “Reimposing Certain Sanctions with Respect to Iran”. The Executive Order was timed to coincide with the last day of the 90-day wind-down period...more

OFAC Officially Revokes Iran General Licenses And Signals Aggressive Enforcement Posture

On June 27, 2018, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) officially revoked General Licenses H and I. General License H previously allowed foreign owned or controlled subsidiaries of...more

President Trump Announces Decision To Withdraw From Iran Nuclear Deal And Reimposition Of Previously Waived Sanctions

President Trump announced today, May 8, 2018, that the United States will withdraw from the Iran Nuclear Deal and will begin reimposing previously waived sanctions on Iran. The deal, formally known as the Joint Comprehensive...more

Russia Sanctions Developments Incite Controversy And Signal Possible Future Changes

Congress enacted the “Countering America’s Adversaries Through Sanctions Act” (CAATSA) on August 2, 2017 in response to Russia’s continuing occupation of the Crimea region of Ukraine and cyber-interference in the 2018 United...more

President Trump Temporarily Extends Iran Nuclear Deal

President Donald Trump has announced that he will approve certain sanctions waivers necessary in order to preserve the Iran nuclear deal (JCPOA). In an official statement, the President indicated that this is the last such...more

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