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
On December 2, 2020, the U.S. House of Representatives passed, by unanimous vote, the Holding Foreign Companies Accountable Act (“HFCAA” or “Act”). Following enactment, foreign issuers, especially Chinese issuers, and their...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
As widely reported, the Standing Committee of the National People’s Congress (the “NPC”) completed its deliberation of and formally promulgated the Law of the People’s Republic of China on Safeguarding National Security in...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
Heightened U.S. national security concerns and trade tensions with China have resulted in new and expanded U.S. regulations that have created barriers for Chinese buyers seeking to acquire assets in the U.S. A number of years...more
At a time of heightened concern about foreign ownership or control of U.S. telecommunication networks and supply chains, President Trump issued an Executive Order (“EO”) on April 4, 2020 formalizing the interagency Team...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
As another sign of the escalating tensions between the United States and China, in addition to the long-running trade war, China this week suspended visits to Hong Kong by the U.S. military and vowed to impose sanctions on a...more
As another sign of the escalating tensions between the United States and China, in addition to the long-running trade war, China this week suspended visits to Hong Kong by the U.S. military and vowed to impose sanctions on a...more
On October 23, 2019, the Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced it was removing three Turkish government ministers and two Turkish government ministries from its list of Specially Designated...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
On August 13, 2018, President Trump signed into law the Foreign Investment Review Risk Modernization Act of 2018 (“FIRRMA”) as part of the John S. McCain National Defense Authorization Act for 2019 (“2019 NDAA”). FIRRMA is...more