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BIS Releases Rules to Revise and Expand Controls Relating to Semiconductors and Advanced Computing

The U.S. Department of Commerce's Bureau of Industry and Security ("BIS") recently released two rules to update export controls on advanced semiconductors, semiconductor development and production, and items that support...more

Impact of Global Sanctions Regimes Relating to Russia, Ukraine, and Belarus

As a response to the Russian invasion of Ukraine starting in late February 2022, Australia, the European Union, Japan, the United Kingdom, the United States, and many other countries have progressively imposed increasingly...more

President Biden Issues Executive Order Modifying Restrictions on U.S. Investment in Chinese Military-Industrial Complex Companies

The Situation: As part of a series of recent executive actions regarding the People's Republic of China ("PRC"), President Biden issued a new executive order on June 3, 2021—Executive Order 14032—that refines novel sanctions...more

Recent Executive Actions Represent Latest Evolution of U.S.-China Relations

President Biden's Executive Orders on China underscore the need for experienced counsel in U.S.-China transactions as the two countries' relations continue to impact the regulatory landscape. On June 9, 2021, President Biden...more

OFAC Guidance on Ransomware Payments Highlights Sanctions Violations Risk

The Situation: In an October 1, 2020, Advisory, the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") warned that companies that make or facilitate ransomware payments to threat actors who are...more

President Trump Expands Sanctions Targeting Maduro Regime - "Embargo" order blocks property of Government of Venezuela and...

On August 5, 2019, President Trump signed Executive Order 13884 ("E.O. 13884") blocking the property of the Government of Venezuela and authorizing sanctions against a range of additional persons. In connection with E.O....more

The Trump Administration Will Not Renew Iranian Oil Waivers

Companies in the banking/financial, energy, logistics, and shipping sectors should assess their operations to mitigate sanctions compliance risks. On Monday, April 22, 2019, the Trump Administration announced that, in the...more

Trump Administration Imposes Further Sanctions on Venezuela, Nicaragua and Cuba; Opens Helms-Burton Act Floodgate

The Situation: On April 17, 2019, the Trump Administration announced additional sanctions targeting the so-called "troika of tyranny" – Venezuela and its key regional allies, Nicaragua and Cuba. These sanctions notably...more

United States Imposes Sanctions on Russia; More Significant Sanctions Possible

The Situation: The U.S. government imposed initial sanctions on Russia under the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991. The sanctions relate to the March 2018 attempted assassination of...more

Impact of U.S. Withdrawal from the Iran Nuclear Deal

The Situation: On Tuesday, May 8, 2018, President Trump announced that the United States has withdrawn from the Iran Nuclear Deal and will fully reimpose its suspended sanctions targeting Iran. The Result: All currently...more

United States' Withdrawal From "Iran Deal" Will Reimpose Sanctions

On May 8, 2018, President Trump announced that the United States would cease participating in the Joint Comprehensive Plan of Action ("JCPOA"), commonly known as the Iran Deal. This will reimpose, by no later than November 5,...more

Revised U.S. Regulations Support Cuba's Private Sector, but Travel Restrictions Remain

The Situation: Regulations implementing tightened U.S. policy towards engagement with Cuba have rolled back a number of Obama-era initiatives and are effective immediately. The Result: Provisions that encourage Cuban...more

Trump Announces New Iran Strategy, Decertifies Iran's Compliance with Iran Nuclear Deal

On Friday, October 13, 2017, President Trump announced that he would not certify that the suspension of sanctions pursuant to the Joint Comprehensive Plan of Action ("JCPOA") (commonly known as the Iran Nuclear Deal) is...more

President Trump Revises U.S. Policy on Cuba

On June 16, 2017, President Trump announced revisions to U.S. policy toward engagement with Cuba and a limited rollback of certain sanctions relief provided by the Obama Administration....more

Potential Options for U.S. Sanctions on Iran Under the Trump Administration

In response to reports that Iran conducted a ballistic missile test launch in February 2017, a former senior U.S. government official announced—and President Trump later echoed over Twitter—that the United States is...more

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