On December 28, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued five new frequently asked questions (“FAQs”) that clarify the scope of Executive Order (“E.O.”) 13959, the basis for OFAC’s...more
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
The United States has for decades utilized its economic clout to pursue sanctions against rogue governments and regimes, terrorists, narcotics traffickers, and human rights abusers. Now, with roughly half a year left in his...more
Earlier this month, the May 1, 2020 Executive Order (EO) on Securing the U.S. Bulk-Power System (BPS) was issued, and we wanted to pass along the following comments/insights about such EO. We find that it is helpful first to...more
As we enter 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) may need time to catch its breath after an exceptionally busy year. 2019 showed us that the Trump Administration continues to rely on...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
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
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
On August 6, 2018, President Trump signed an executive order (“New Iran E.O.”) directing the Secretaries of State and the Treasury to re-impose sweeping sanctions on Iran, effecting the policy announced on May 8, 2018, to...more
On April 6, 2018, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) added 38 new designees to its list of Specially Designated Nationals and Blocked Persons (“SDN List”) related to Russia pursuant to...more
In This Issue:
- The New Front in U.S. Sanctions: Ukraine and Russia
- Electronic Invoicing in EU Public Contracts
- German and EU Rules on Joint Bids
- Q+A Corner with Melissa Milstead, Associate General...more