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
12/15/2020
/ CAATSA ,
China ,
Export Controls ,
Hong Kong ,
NATO ,
NDAA ,
Pentagon ,
Pipelines ,
Russia ,
Sanctions ,
Trump Administration ,
Turkey ,
US Department of State
On January 6, 2020, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published an interim final rule amending the Export Administration Regulations (EAR) to place new restrictions on the export of...more
On December 13, 2019, the Department of Justice’s National Security Division (“NSD”) announced a revised policy to encourage voluntary self-disclosures (“VSDs”) of criminal violations of export control and sanctions laws. The...more
As it nears the end of the calendar and legislative year, Congress is preparing to take long-awaited action to kill Russia’s Nord Stream 2 and TurkStream natural gas pipeline projects – months before Nord Stream 2’s...more
As another sign of the escalating tensions between the United States and China, in addition to the long-running trade war, China this week suspended visits to Hong Kong by the U.S. military and vowed to impose sanctions on a...more
As another sign of the escalating tensions between the United States and China, in addition to the long-running trade war, China this week suspended visits to Hong Kong by the U.S. military and vowed to impose sanctions on a...more
On September 24, 2019, the U.S. Department of the Treasury ("Treasury") published in the United States Federal Register the proposed regulations developed by the United States Committee on Foreign Investment (CFIUS) to...more
BID PROTESTS, LATEST DEVELOPMENTS & TWISTS -
Bid Protests: Agenda -
1. LOGCAP V and Task/Delivery Order Protest Jurisdiction
2. SpaceX and Other Transaction Authority Protest Jurisdiction
3. Potential Impact of New...more
On October 23, 2019, the Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced it was removing three Turkish government ministers and two Turkish government ministries from its list of Specially Designated...more
On October 14, President Trump issued an Executive order (“E.O.”) imposing sanctions on Turkey in response to Turkey’s military offensive in northern Syria. New E.O. 13894 authorizes the U.S. Departments of State and the...more
This is the third in our multipart series of alerts addressing proposed regulations published in the Federal Register on September 24, 2019, for the Committee on Foreign Investment in the United States (CFIUS) to implement...more
The U.S. Department of Commerce (“Commerce”) has added 28 Chinese organizations to the Bureau of Industry and Security (BIS) Entity List, a move that effectively cuts off these entities from directly or indirectly acquiring...more
This is the second in our multipart series of alerts addressing proposed regulations published in the Federal Register on September 24, 2019, for the Committee on Foreign Investment in the United States (CFIUS) to implement...more
As part of the 18th anniversary of the September 11 attacks earlier this month, the Trump Administration effectively declared the old adage that “one person’s terrorist is another person’s freedom fighter” does not apply with...more
Nearly a quarter century after its passage, the Cuban Liberty and Democratic Solidarity (Libertad) Act of 1996 – commonly known as Helms-Burton, after its sponsors – was expected to revive a significant number of old disputes...more
The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) has a well-earned reputation in the sanctions bar for ruining weekends. The agency responsible for implementing and enforcing U.S. economic sanctions has...more
On May 2, 2019, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) published its first-ever Framework for OFAC Compliance Commitments (“Framework”), detailing the essential components of a sanctions...more
Back in February, we told you about the Defending American Security from Kremlin Aggression Act, or “DASKA,” a bipartisan effort to impose new sanctions on Russia. Interest in action against the Kremlin has only increased...more
An Attempt to Limit the Strain on the Telecom Sector, but Broad Prohibition on Exports Remains -
The Department of Commerce Bureau of Industry and Security (BIS) has issued a 90-day temporary general licenseexempting a set...more
With tensions rising in the Persian Gulf, and Iran on the brink of pulling out of portions of the Iran nuclear deal, President Trump issued new Executive Order 13871 last Wednesday, May 8, 2019, imposing sanctions on Iran’s...more
Since it was enacted in March 2018, the Clarifying Lawful Overseas Use of Data Act (CLOUD Act) has been controversial with privacy advocates in the United States and the subject of sustained criticism by the European...more
The Committee on Foreign Investment in the United States (CFIUS) has proven in recent weeks that it is an increasingly powerful force that foreign investors and U.S. businesses alike ignore at their peril. While many paid...more
On a bizarre day for sanctions that saw President Trump seemingly take action related to North Korea via tweet – revoke recent measures? scuttle pending ones? – the U.S. Treasury Department’s Office of Foreign Assets Control...more
In another indication of the U.S. Department of Justice’s increased focus on the Foreign Agents Registration Act (FARA), Assistant Attorney General John Demers announced that the Department is overhauling its FARA enforcement...more
UPDATE: Two days after we issued our Top 20 sanctions compliance lessons from recent OFAC enforcement cases, OFAC issued an unprecedented enforcement one-two punch. On February 7, 2019, OFAC settled an enforcement case with...more