The Uyghur Forced Labor Prevention Act (the UFLPA) came into effect last week, and US Customs and Border Protection (CBP) and US Department of Homeland Security (DHS) have released guidance for importers for demonstrating...more
7/5/2022
/ Biden Administration ,
China ,
Compliance ,
Customs and Border Protection ,
Department of Homeland Security (DHS) ,
Effective Date ,
Entity List ,
Forced Labor ,
Importers ,
Imports ,
New Guidance ,
Rebuttable Presumptions ,
Supply Chain ,
Uyghur Forced Labor Prevention Act (UFLPA)
Today, the Biden Administration took two separate, complementary actions in a response to intense political pressure arising from the ongoing dispute between domestic solar project developers and domestic solar module...more
6/7/2022
/ Anti-Dumping Duty ,
Biden Administration ,
Countervailing Duties ,
Defense Production Act ,
Electricity ,
Energy Projects ,
Energy Sector ,
Imports ,
Manufacturers ,
Power Grid ,
Renewable Energy ,
Solar Energy ,
Solar Panels ,
State of Emergency ,
Tariff Act of 1930 ,
U.S. Commerce Department
Following the invasion of Ukraine by Russia, the UK, EU and US have all responded by announcing significant sanctions in respect of Russia and Belarus.
This briefing summarises the key developments since 25 April 2022 and...more
Asset Freezes -
On 13 and 14 April 2022, the UK imposed asset freezes with respect to 208 individuals. This included alleged separatists, oligarchs, close associates and employees of oligarchs and individuals who have...more
After reports of humanitarian atrocities and further details of the continued Russian aggression in Ukraine emerged over the weekend, the United States and its allies responded with further sanctions and export controls. “The...more
Following the invasion of Ukraine by Russia, the UK, EU and US have all responded by announcing significant sanctions in respect of Russia and Belarus.
The sanctions landscape has been changing at a fast pace and further...more
3/23/2022
/ Asset Freeze ,
Belarus ,
Blocked Entities ,
Blocked Person ,
Economic Sanctions ,
Entity List ,
EU ,
Export Controls ,
Foreign Relations ,
General Licenses ,
Russia ,
SDN List ,
Switzerland ,
UK ,
Ukraine
On March 7, 2022, the Financial Crimes Enforcement Network (FinCEN) issued an alert calling on financial institutions to be “vigilant” in guarding against attempts to evade the recent imposition of expanded Russia sanctions....more
3/21/2022
/ Anti-Money Laundering ,
Compliance ,
Economic Sanctions ,
Financial Institutions ,
FinCEN ,
Office of Foreign Assets Control (OFAC) ,
Reporting Requirements ,
Risk Management ,
Russia ,
Terrorist Financing Regulations ,
Virtual Currency
In the latest action to expand sanctions against Russia in response to its invasion of Ukraine, on March 8, 2022, President Biden announced in a televised speech a ban on imports of Russian oil, natural gas, and coal into the...more
3/11/2022
/ Biden Administration ,
Economic Sanctions ,
Executive Orders ,
Foreign Relations ,
General Licenses ,
Imports ,
Magnitsky Act ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Russia ,
Tariffs ,
WTO
The US Department of the Treasury (Treasury) has released the results of its review of economic and financial sanctions first announced in December 2020 by then President-elect Biden (Report). From that review, Treasury has...more
On September 21, 2021, the US Department of the Treasury took actions in response to the increasing prevalence and severity of ransomware attacks in the United States and address the central role that virtual currency and...more
9/27/2021
/ Currency Exchange ,
Cybersecurity ,
Cybersecurity Information Sharing Act (CISA) ,
Digital Currency ,
Economic Sanctions ,
Enforcement Actions ,
Office of Foreign Assets Control (OFAC) ,
Ransomware ,
SDN List ,
U.S. Treasury ,
Virtual Currency
On Monday, August 9, 2021, the Office of Foreign Assets Control (OFAC) of the US Department of the Treasury issued a multitude of sanctions designations affecting dealings with Belarusian companies in the construction, oil,...more
On July 9, 2021, President Biden signed the Executive Order on Promoting Competition in the American Economy. The Order, breathtaking in scope, asserts as a key goal the desire to improve the lives of consumers through...more
7/21/2021
/ Anti-Competitive ,
Biden Administration ,
Competition ,
Consumer Financial Protection Bureau (CFPB) ,
Department of Agriculture ,
Department of Health and Human Services (HHS) ,
Dodd-Frank ,
Employer Liability Issues ,
Employment Contract ,
Executive Orders ,
FCC ,
Federal Reserve ,
Federal Trade Commission (FTC) ,
Financial Services Industry ,
Insurance Industry ,
Non-Compete Agreements ,
Popular ,
Regulatory Agencies ,
Restrictive Covenants ,
Technology Sector ,
Unfair Labor Practices
In 2019, the US imposed sanctions against China in reaction to “serious human rights abuse against ethnic minorities in Xinjiang...” The sanctions followed reports of mass arbitrary detention and severe physical abuse, among...more
6/16/2021
/ Biden Administration ,
China ,
Economic Sanctions ,
Exports ,
Forced Labor ,
Human Rights ,
Office of Foreign Assets Control (OFAC) ,
Rare Earth Metals ,
SDN List ,
Slavery ,
Solar Panels ,
Supply Chain
On June 3, 2021, in one of his first major China-related actions, President Biden issued an Executive Order that amends, but keeps intact the core elements of, previous orders issued by President Trump prohibiting US Persons...more
6/7/2021
/ Biden Administration ,
China ,
Department of Defense (DOD) ,
Exemptions ,
Foreign Investment ,
Human Rights ,
Military End Use ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Prohibited Transactions ,
SDN List ,
Technology Sector ,
Telecommunications ,
U.S. Treasury
While the Biden Administration desires a “stable and predictable” relationship with Russia, it has now made it clear that it will take “actions to impose costs on Russia for actions by its government and intelligence services...more
4/22/2021
/ Biden Administration ,
Blocked Entities ,
Blocked Person ,
Blocking Sanctions ,
Crimea ,
Economic Sanctions ,
Executive Orders ,
Foreign Policy ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia
On March 25, 2021, in its effort to intensify international pressure on Min Aung Hlaing’s military government, the US placed sanctions, pursuant to Executive Order 14014, on two holding companies, Myanma Economic Holdings...more
In the latest of a series of measures targeting China before this week’s transition of administrations, on January 14, 2021, the Trump Administration added China National Offshore Oil Corporation Ltd. (CNOOC) to the US...more
On November 12, 2020, President Trump issued an executive order (Order) that effectively prohibits US persons from transacting in publicly traded securities of Chinese firms determined by the US government to be owned or...more
On June 2, 2020, the Office of the United States Trade Representative (USTR) announced that it is beginning investigations under Section 301 of the Trade Act of 1974 (Trade Act) into digital services taxes (DSTs) that have...more
On May 1, 2020, President Trump issued an “Executive Order on Securing the United States Bulk-Power System,” aimed at preventing cyberattacks to and interference by foreign adversaries with the US power grid. Specifically,...more
In response to shortages of Personal Protective Equipment (PPE) critical to limiting the spread of and mitigating the impact of COVID-19, the United States has recently issued a series of rules, memoranda, and other guidance...more
4/22/2020
/ Coronavirus/COVID-19 ,
Customs and Border Protection ,
Enforcement Guidance ,
Exports ,
FEMA ,
Food and Drug Administration (FDA) ,
Imports ,
Medical Equipment ,
Personal Protective Equipment ,
Tariffs ,
USTR
This briefing is intended to provide an update on two recent developments under the US sanctions regime.
..The first one is the introduction of US sanctions related to the Nord Stream 2 pipeline project, which threaten to...more
1/30/2020
/ Administrative Procedure Act ,
Blocking Sanctions ,
Civil Monetary Penalty ,
Construction Industry ,
Contract Formation ,
Defense Sector ,
Economic Sanctions ,
Energy Projects ,
Energy Sector ,
Enforcement Actions ,
EU ,
Exxon Mobil ,
Fair Notice ,
Federal Budget ,
Foreign Policy ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Pipelines ,
Prohibited Transactions ,
Russia ,
SDN List ,
Summary Judgment ,
Vessels
The extraterritorial reach of statutes seeking to prohibit unscrupulous financial practices has been debated and watched as both entities and individuals seek to determine the scope of the United States’ government’s ability...more
Consistent with the ongoing United States (US) strategy of limiting engagement with China in the high-tech sector (especially telecommunications) on national security grounds, the US Department of Commerce’s Bureau of...more
6/3/2019
/ Bureau of Industry and Security (BIS) ,
China ,
Entity List ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Huawei ,
Licensing Rules ,
National Security ,
Prohibited Transactions ,
Supply Chain ,
Technology Sector ,
Telecommunications ,
Trump Administration ,
U.S. Commerce Department
On May 2, 2019, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued guidance titled “A Framework for OFAC Compliance Commitments” (Guidance), providing direction regarding what OFAC considers to...more
5/15/2019
/ Anti-Money Laundering ,
Audits ,
Chief Compliance Officers ,
Compliance ,
Corporate Governance ,
Corporate Management ,
Department of Justice (DOJ) ,
Dubai ,
Enforcement ,
Enforcement Actions ,
Enforcement Authority ,
Financial Conduct Authority (FCA) ,
Financial Industry Regulatory Authority (FINRA) ,
Foreign Corrupt Practices Act (FCPA) ,
Guidance Update ,
Hong Kong ,
Hong Kong Securities and Futures Commission (HKSFC) ,
Internal Controls ,
Monetary Authority of Singapore ,
Office of Foreign Assets Control (OFAC) ,
Personal Liability ,
Risk Assessment ,
Securities and Exchange Commission (SEC) ,
Singapore ,
Training ,
U.S. Treasury ,
UK