On February 20, 2026, the United States Supreme Court struck down one of President Trump’s signature second-term initiatives — the April 2, 2025, Liberation Day Tariffs — in six words: “Those words cannot bear such weight.”...more
Last week Bracewell discussed the Trump administration’s initial easing of restrictions on Venezuelan oil with General License (GL) 46, which opened the door for US companies to revive the long-inaccessible industry. However,...more
Hours after the US military strike that ousted Venezuelan President Nicolas Maduro, President Trump announced that, “very large US oil companies, the biggest anywhere in the world” would “go in, spend billions of dollars, fix...more
2/4/2026
/ Economic Sanctions ,
Energy Sector ,
Export Controls ,
General Licenses ,
International Trade ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Popular ,
Trump Administration ,
U.S. Treasury ,
US Trade Policies
Last month Bracewell highlighted the latest sets of Russia-related sanctions imposed by the United Kingdom, European Union and United States, explaining the potential far-reaching implications of what are the strongest...more
11/25/2025
/ Compliance ,
Compliance Management Systems ,
Due Diligence ,
Economic Sanctions ,
Energy Sector ,
Export Controls ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Risk Management ,
Russia
In August, Bracewell discussed the evolving impact of UK and EU sanctions on corporations in the energy and infrastructure sectors. In a significant escalation, in October, the UK, US and EU changed the landscape again by...more
In March 2025, British, French and Swiss authorities announced a new international alliance – the International Anti-Corruption Prosecutorial Taskforce (“Taskforce”) — to tackle bribery and corruption...more
Federal law has long required recipients of federal funds to comply with anti-discrimination laws. Over the last decade, initiatives under the label Diversity, Equity and Inclusion (“DEI”) became a widespread vehicle for...more
President Trump has used tariffs as a significant point of geopolitical leverage since the beginning of his second term. Indeed, his administration dubbed April 2, 2025 “Liberation Day” in honor of a sweeping set of tariffs...more
4/9/2025
/ China ,
Economic Sanctions ,
Energy Sector ,
Executive Orders ,
Human Rights ,
Imports ,
International Trade ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Tariffs ,
Trump Administration ,
U.S. Treasury ,
Venezuela
As discussed in Bracewell’s February 11 and February 26 updates, the executive branch is prioritizing the “total elimination” of cartels and transnational criminal organizations, both through edicts from the Oval Office and...more
4/3/2025
/ Anti-Money Laundering ,
Cartels ,
Civil Liability ,
Criminal Liability ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Financial Institutions ,
International Emergency Economic Powers Act (IEEPA) ,
Mexico ,
Money Laundering ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Terrorist Organizations ,
Trump Administration
The US State Department has made its first round of designations pursuant to Executive Order 14157, “Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists,”...more
2/27/2025
/ Anti-Corruption ,
Corporate Counsel ,
Criminal Prosecution ,
Economic Sanctions ,
Executive Orders ,
Foreign Entities ,
Foreign Investment ,
Foreign Policy ,
Office of Foreign Assets Control (OFAC) ,
Risk Management ,
Terrorism Funding
Shortly after President Trump’s second inauguration, his executive branch took steps to further one of his signature promises: securing the southern border. While these actions primarily impact immigration laws, several...more
On January 10, 2025, in a final action to, among other things, deter Russian aggression on the international stage, the US Department of the Treasury enacted sweeping new sanctions on the Russian energy sector. Specifically,...more
1/17/2025
/ Biden Administration ,
Blocking Sanctions ,
Economic Sanctions ,
Energy Sector ,
General Licenses ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Petroleum ,
Popular ,
Renewable Energy ,
Russia ,
Sanctions ,
SDN List ,
U.S. Treasury
After years of suggesting that modifications were in the works, the Department of Justice recently proposed drastic changes to the Foreign Agents Registration Act (FARA) that would, among other things, profoundly limit one of...more
1/3/2025
/ Advisory Opinions ,
Department of Justice (DOJ) ,
Disclosure Requirements ,
Enforcement ,
Foreign Agents Registration Act (FARA) ,
Foreign Governments ,
Lobbying ,
Notice of Proposed Rulemaking (NOPR) ,
Political Parties ,
Proposed Regulation ,
Social Media ,
Transparency ,
Websites
On November 26, 2024, the US Court of Appeals for the Fifth Circuit ruled that “immutable” smart contracts are not “property” for purposes of regulation by the US Department of the Treasury’s Office of Foreign Assets Control...more
12/19/2024
/ Appeals ,
Biden Administration ,
Blockchain ,
Chevron Deference ,
Cryptocurrency ,
Decentralized Autonomous Organization (DAO) ,
Decentralized Finance (DeFi) ,
Digital Assets ,
Economic Sanctions ,
Executive Orders ,
International Emergency Economic Powers Act (IEEPA) ,
Loper Bright Enterprises v Raimondo ,
Office of Foreign Assets Control (OFAC) ,
SCOTUS ,
SDN List ,
Smart Contracts
As the world prepares for the change of administration in January, current government officials and industry experts convened at the New York Forum on Economic Sanctions to reflect on enforcement trends in 2024, and to...more
12/10/2024
/ Anti-Money Laundering ,
Banks ,
Bureau of Industry and Security (BIS) ,
Cryptocurrency ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
National Security ,
Nuclear Weapons ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Self-Disclosure Requirements ,
Technology ,
Voluntary Disclosure
On September 23, 2024, Principal Deputy Assistant Attorney General Nicole Argentieri announced that the US Department of Justice (DOJ) had issued updated guidance to federal prosecutors in its “Evaluation of Corporate...more
10/4/2024
/ Artificial Intelligence ,
Clawbacks ,
Compensation ,
Compliance ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Due Diligence ,
Emerging Technologies ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Good Faith ,
Incentives ,
Mergers ,
Risk Assessment ,
Risk Management ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
Whistleblower Awards ,
Whistleblower Hotlines ,
Whistleblowers
As we wrote earlier this month, the Department of Justice (DOJ) made significant news at the recent American Bar Association White Collar Conference. But the Department didn’t stop at announcing its pilot whistleblower...more
3/28/2024
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
American Bar Association (ABA) ,
Data Protection ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
FEPA ,
Foreign Corrupt Practices Act (FCPA) ,
National Security ,
Penalties ,
Recidivism ,
Whistleblowers ,
White Collar Crimes
In recent years, the Department of Justice (DOJ) has rolled out a significant and increasing number of carrots and sticks aimed at deterring and punishing white collar crime. Speaking at the American Bar Association White...more
3/13/2024
/ CFTC ,
Department of Justice (DOJ) ,
Disclosure Requirements ,
Employee Misconduct ,
FinCEN ,
Foreign Corrupt Practices Act (FCPA) ,
Incentives ,
IRS ,
Qui Tam ,
Securities and Exchange Commission (SEC) ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
Whistleblowers ,
White Collar Crimes
As lawyers, corporate executives and federal law enforcement officials prepare to gather this week in San Francisco for the ABA’s 39th National Institute on White Collar Crime, we offer our takeaways from January’s Houston...more
3/5/2024
/ Anti-Corruption ,
Cannabis Products ,
Compliance ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement ,
Environmental Social & Governance (ESG) ,
Foreign Corrupt Practices Act (FCPA) ,
Incentives ,
Investment ,
Market Manipulation ,
Office of Foreign Assets Control (OFAC) ,
San Francisco ,
Securities and Exchange Commission (SEC) ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
Whistleblowers ,
White Collar Crimes ,
Wire Fraud
2023 was a banner year in the sanctions space and regulators seem primed to continue that performance in 2024. In December 2023, numerous government officials and industry experts convened at the New York Forum on Economic...more
1/12/2024
/ Bureau of Industry and Security (BIS) ,
CFTC ,
Compliance ,
Economic Sanctions ,
Enforcement ,
European Anti-Fraud Office (OLAF) ,
Export Administration Regulations (EAR) ,
Export Controls ,
FinCEN ,
Foreign Corrupt Practices Act (FCPA) ,
National Security ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Self-Disclosure Requirements ,
Suspicious Activity Reports (SARs) ,
Voluntary Disclosure ,
Whistleblowers
The past few months have seen numerous high-profile enforcement actions highlighting an increasing trend, what Deputy Attorney General Lisa Monaco called “the biggest shift in corporate criminal enforcement that I’ve seen...more
12/5/2023
/ Acquisitions ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Corporate Crimes ,
Corporate Misconduct ,
Cryptocurrency ,
Cyber Crimes ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Intellectual Property Protection ,
Investigations ,
Mergers ,
National Security ,
Recidivism ,
Remediation ,
Sanction Violations ,
Self-Disclosure Requirements ,
Terrorist Financing ,
Voluntary Disclosure ,
Whistleblowers
Federal regulators have cracked down on the use of texts messages and messaging platforms for business communications, using their broad authority to root out record retention violations, resulting in significant fines and...more
10/20/2023
/ Broker-Dealer ,
CFTC ,
Compliance ,
Email ,
Enforcement Actions ,
FERC ,
Financial Industry Regulatory Authority (FINRA) ,
Fines ,
Insider Trading ,
Instant Messaging Apps ,
Investment Adviser ,
Mobile Devices ,
Multi-Factor Authentication ,
Policies and Procedures ,
Record Retention ,
Regular Business Communications ,
Sanctions ,
Securities and Exchange Commission (SEC) ,
Software ,
Text Messages
On July 26, 2023, the Securities and Exchange Commission (“SEC”) issued a final rule that requires registrants to provide enhanced and standardized disclosures regarding “cybersecurity risk management, strategy, governance...more
8/29/2023
/ Cryptoassets ,
Cyber Incident Reporting ,
Cyber Threats ,
Cybersecurity ,
Final Rules ,
Form 10-K ,
Materiality ,
Ransomware ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act of 1934
Last week, Attorney General Merrick Garland issued a new DOJ charging and sentencing policy memorandum, replacing existing guidance to federal prosecutors in their exercise of prosecutorial discretion. The thrust of the...more
In its continued efforts to enhance the cybersecurity of transportation and other critical infrastructure systems across the country, the Transportation Security Administration (TSA) issued on October 19, 2022 a new security...more