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Do April Tariff Showers Bring May Trade Deal Flowers?

Following the introduction and partial rescission of the “Liberation Day” tariffs last month, the latest U.S. government actions have largely—though not universally—continued down the path of an easing tariff burden. Of...more

Tariff Update: Increased China Tariffs, New Tariff Exemptions, a Temporary 90-Day Pause on Most Reciprocal Tariffs, and Thoughts...

On April 9, 2025, exactly one week after the announcement of his “Liberation Day” tariffs, President Trump issued a new Executive Order (“Modifying Reciprocal Tariff Rates to Reflect Trade Partner Retaliation and...more

Understanding the "Liberation Day" Tariffs

On April 2, 2025, President Trump signed a new Executive Order (the “Liberation Day EO”) implementing additional tariffs on almost all U.S. trading partners, invoking the International Emergency Economic Powers Act (IEEPA)....more

New BIS Rule Expands Export Controls and Due Diligence Requirements for Advanced Computing Integrated Circuits

As part of its ongoing efforts to thwart China's development of advanced computing technologies, the U.S. Department of Commerce's Bureau of Industry and Security (BIS) issued an interim final rule (the IFR) last month that...more

Duty Calls . . . and It’s Collect: President Trump Imposes Stiff New Tariffs on Canada, Mexico, and China

On February 1, 2025, President Trump signed new executive orders targeting Canada, Mexico, and China, implementing the first set of tariffs under his new administration. Citing concerns over human trafficking, illicit drug...more

BIS Implements New Controls on Additive Manufacturing, Quantum Computing, and Advanced Semiconductor Manufacturing

On September 6, 2024, the Bureau of Industry and Security (BIS) issued an interim final rule (the September 6 IFR) implementing new and revised export controls relating to emerging or critical technologies in the fields of...more

Biden Administration Further Expands Export Controls and Sanctions on Russia and Belarus

On June 12, 2024, ahead of the 2024 G7 Summit, the Biden administration introduced new export controls and sanctions on Russia and Belarus in an effort to limit Russia’s ability to continue its war efforts against Ukraine....more

DOJ Sues SpaceX in Continuing Campaign Against Use of Export Controls to Justify Employment Discrimination

On August 24, 2023, the U.S. Department of Justice (DOJ) filed a complaint against Space Exploration Technologies Corporation (SpaceX) for its alleged violations of the Immigration and Nationality Act’s (INA) prohibition on...more

OFAC Penalizes Another Crypto Asset Company for Sanctions Violations

In keeping with its recent focus on the crypto asset industry, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced an agreement last week with crypto asset trading platform Poloniex, LLC...more

Coinbase Agrees to Pay $100 Million and Improve Compliance Program as Regulators Continue Scrutiny of Crypto Asset Companies

The consent order issued by the New York Department of Financial Services (NYDFS) to crypto asset exchange, Coinbase, serves as a reminder of regulators’ growing interest in ensuring that crypto asset companies meet their...more

Crypto Exchange Agrees to Pay More Than $362,000 to Settle Alleged Sanctions Violations

On November 28, 2022, the U.S. Treasury’s Office of Foreign Assets Control (OFAC) announced that Payward, Inc. d/b/a Kraken, a U.S.-based cryptocurrency exchange, agreed to pay $362,158.70 to settle charges relating to its...more

Cryptocurrency Exchange Platform Agrees to Pay over $53 Million for Anti-Money Laundering and Sanctions Violations

On October 11, 2022, the U.S. Treasury's Financial Crimes Enforcement Network (FinCEN) and Office of Foreign Assets Control (OFAC) announced settlements with Bittrex Inc. (Bittrex). The settlements arise from violations of...more

Compliance Reminder: SEC Disclosure Considerations Arising from Russia's Invasion of Ukraine

Many public companies are beginning preparations for filing quarterly reports on Form 10-Q for the second quarter of calendar 2022. As they do so, they should review and consider the U.S. Securities and Exchange Commission...more

No Foolish Transactions: A Few Guidelines for NFT Marketplace Participants to Mitigate Anti-Money Laundering Risks

The global NFT (non-fungible token) market now is worth dozens of billions of dollars annually. Innovators and early adopters, marketplaces, and sellers, are all eager to join this market but may have questions about how to...more

U.S. State Department Proposes ITAR Revisions to Remove Prior Citizenship Status Considerations

The U.S. State Department has proposed revisions to multiple sections of the International Traffic in Arms Regulations (ITAR) to remove consideration of citizenships previously held by a foreign person. The State Department's...more

CJEU Publishes Judgment Interpreting the EU’s Blocking Regulation

In December 2021, the Court of Justice of the European Union (the CJEU) published a judgment interpreting the European Union's Blocking Regulation....more

New OFAC Guidance Raises the Stakes for Crypto Industry

The U.S. Treasury Department's Office of Foreign Assets Control (OFAC) published new guidance last week for the virtual currency industry. While OFAC's economic sanctions compliance obligations apply to all U.S. persons, the...more

Know Your Customer: OFAC, BIS Penalize Companies for Sales of “EAR99” Items and Services to Prohibited Parties Through...

The U.S. government recently took action in two cases against companies for exports to distributors that resold their products to prohibited parties. The products at issue in both cases are designated "EAR99," which is a...more

Electronics Testing Company Penalized $6.6 Million for Unauthorized Software Exports

The U.S. State Department's Directorate of Defense Trade Controls (DDTC) reached a $6.6 million settlement last week with California-based electronics testing company Keysight Technologies, Inc. for alleged illegal exports of...more

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