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OFAC Year in Review 2021 – Part 1

2021 was a year of transition in the United States and for the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). OFAC’s year, while busy, was far different from 2020, as the Biden Administration’s...more

Sanctions Legislation Watch: What to Expect from Congress as 2021 Comes to a Close

As we approach year’s end, and the pace of legislative activity ramps up, it remains critical to keep a close eye on the sanctions-related bills currently making their way, at varying speeds, through the U.S. legislative...more

China’s New Anti-Foreign Sanctions Law: Understanding Its Scope And Potential Liabilities

China’s new Anti-Foreign Sanctions Law (AFSL) (中华人民共和国反外国制裁法) achieves two goals. First, it creates a menu of countersanctions available to Chinese authorities—visa restrictions, asset and transaction blocks within...more

OFAC 2020 Year In Review

In too many ways to count, 2020 was an extraordinary year. As we move into 2021 with optimism for an end to the pandemic and better days ahead, we understand that the activity last year of the U.S. Department of the...more

Trump Administration Continues Its Aggressive Approach Toward Chinese Military Company Sanctions

Former US President Trump during his term of office only a week, before the release of its 13959 No. Executive Order ( "Executive Order") has been modified . The previous executive order prohibits Americans from investing in...more

The Potential Impact Of The Blocking Measures Recently Issued By The Ministry Of Commerce On Chinese And Foreign Companies

China’s recently promulgated Measures to Block the Improper Extraterritorial Application of Foreign Laws and Measures (the “Measures”) has established a new framework for mitigating the impact of foreign legal measures,...more

New Blocking Rules By China’s MOFCOM Create New Risks for Chinese And Foreign Companies

China’s new Rules on Counteracting Unjustified Extraterritorial Application of Foreign Legislation and Other Measures (《阻断外国法律与措施不当域外适用办法》) (the “Rules”) create a new framework to mitigate the impact of foreign legal...more

Trump Administration Continues Its Aggressive Approach Toward Chinese Military Company Sanctions

With just one week remaining in his term, President Trump amended Executive Order (“EO”) 13959, which prohibits U.S. persons from investing in the securities of Chinese Military Companies (“CMCs”), to continue his aggressive...more

Defense Bill Aims Additional Sanctions At Turkey, Russia, And China

One of the widest-ranging bills of the U.S. Congress’s legislative year, the National Defense Authorization Act for Fiscal Year 2021 (NDAA), is nearing the finish line as both the House and Senate overwhelmingly approved the...more

Trump Administration Gives Teeth To Pentagon List And Restricts U.S. Investment In Publicly Traded Securities Of Chinese Military...

Over the past summer, prompted by a bipartisan Congressional letter identifying a two‑decade‑old statute as an unused tool in confronting China’s strategy of “Military-Civilian Fusion,” the U.S. Department of Defense (“DOD”)...more

Hong Kong In The Crosshairs: Secretary Of State Submits Hong Kong Autonomy Act Report To Congress, Paving Path For Secondary...

On Wednesday, October 14, 2020, the U.S. Department of State (“State”) submitted a report to the U.S. Congress, as required under section 5(a) of the Hong Kong Autonomy Act (“HKAA”), identifying foreign persons materially...more

Sanctions Followed: A New Round Of Sanctions Against China And Russia

As the new crown virus is spreading and there have been many demonstrations that "blacks are also fate," the US Congress has increased its work during the election year, threatening to strengthen sanctions against China and...more

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