Nicholas Spiliotes on National Security

OFAC Has Been Talking About Compliance Through Enforcement - Have You Been Listening?

Last Thursday, January 31, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued its first enforcement action of 2019, a fascinating case involving false eyelashes that teaches that virtually any...more

2/5/2019 / CFIUS , Compliance , Corporate Counsel , Economic Sanctions , Export Controls , National Security , Office of Foreign Assets Control (OFAC)

OFAC Designates PDVSA to Initiate End Game in Venezuela

In what was perhaps an inevitable escalation, on Monday, January 28, 2019, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) imposed sanctions on Venezuelan state-owned oil and gas company Petróleos de...more

2/1/2019 / CFIUS , Economic Sanctions , Export Controls , National Security , Office of Foreign Assets Control (OFAC) , Oil & Gas , SDN List , Venezuela

OFAC Delists Oligarch Companies Over Congressional Objections

On Sunday, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced that it lifted sanctions on three entities associated with Russian oligarch Oleg Deripaska, including the second-largest aluminum...more

1/29/2019 / CAATSA , CFIUS , Economic Sanctions , Export Controls , Exports , National Security , Office of Foreign Assets Control (OFAC) , Russia , SDN List

Opportunity to Comment on Emerging Technologies Subject to Future Export and Investment Restrictions

The Department of Commerce’s Bureau of Industry and Security (BIS) issued an Advance Notice of Proposed Rulemaking (ANPRM or the “Notice”) on November 19, 2018, concerning the list of “emerging and foundational technologies”...more

11/21/2018 / Advanced Notice of Proposed Rulemaking (ANPRM) , Bureau of Industry and Security (BIS) , CFIUS , Export Controls , Investment , National Security

Iran Sanctions: Snap-Back, Part 2

Executive Summary - On November 5, 2018, the United States enacted the second of two powerful phases of the “snap-back” of Iran sanctions, re-imposing sanctions that were lifted by the United States in 2016 as a result of...more

11/9/2018 / Crisis Management , Export Controls , Iran , Iran Sanctions , Joint Comprehensive Plan of Action (JCPOA) , National Security

New CFIUS Pilot Program Expands U.S. Government Review of Tech Transactions

The Foreign Investment Risk Review Modernization Act of 2018 (“FIRRMA”), which became law on August 13, 2018, effected sweeping change to the authority and processes of the Committee on Foreign Investment in the United States...more

10/15/2018 / CFIUS , FIRRMA , Foreign Investment , Investment , National Security

Revised CFIUS Bill Receives Unanimous Approval in House and Senate Committees; Increases Export Controls for “Critical...

Legislation that would substantially overhaul the law governing the Committee on Foreign Investment in the United States (CFIUS) received unanimous committee approvals in the House and Senate today. The proposed legislation...more

5/24/2018 / CFIUS , Corporate Counsel , Export Controls , FIRRMA , Foreign Investment , National Security

OFAC’s New Russia-Related Sanctions

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

4/19/2018 / CAATSA , Capital Markets , Economic Sanctions , Executive Orders , National Security , Office of Foreign Assets Control (OFAC) , Russia , SDN List

Congress to Consider a Broad Overhaul of CFIUS

On November 8, 2017, bipartisan coalitions in both the House and the Senate announced new legislation that would substantially overhaul current law governing the Committee on Foreign Investment in the United States (CFIUS)...more

11/10/2017 / CFIUS , Cybersecurity , Foreign Investment , National Security

Nicholas Spiliotes

Morrison & Foerster LLP

Popular Topics by This Author

Latest Posts › National Security