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Inside New Commerce Tech Restrictions: Mitigation Strategies

The U.S. Department of Commerce’s Bureau of Industry and Security has issued the final rule that will determine how its Information and Communications Technology and Services regulations will work going forward....more

US Modifies Reciprocal Tariff Rates

President Trump signed a new executive order, “Modifying Reciprocal Tariff Rates to Reflect Trading Partner Retaliation and Alignment” (the Order) on April 9, marking yet another significant shift in U.S. trade policy. The...more

Trump Administration’s First Export Control Action – Reading the Tea Leaves

On March 25, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced a significant expansion of its Entity List restrictions, adding 80 entities from China, the United Arab Emirates, South Africa,...more

Unprecedented "Secondary Tariffs" for Oil Trade With Venezuela

On April 2 — labeled “Liberation Day” by President Trump — the Trump administration is set to add a new sanctions-like boost to its tariff strategy, with a threat to impose unprecedented “secondary tariffs” of 25% on “all...more

Foreign Influence in Universities Targeted by Trump Administration

As part of the “America First” Investment Policy Memorandum, released on February 21, the Trump administration signaled that it may increase restrictions on investments made by American university endowments relating to...more

Financial Transactions Related to Russian Energy Now Prohibited: Expiration of OFAC ‎General License 8L

On March 12, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) allowed General License (GL) 8L under the Russian Harmful Foreign Activities Sanctions Regulations to expire. As a result, broad OFAC...more

Latest Sanctions Developments: Venezuela, Russia, and Yemen

The Trump administration continues to ramp up sanctions on Venezuela and Yemen's Houthis, while sending mixed signals about its intentions with respect to Russia. We provide brief updates on these three areas, following up...more

US Declares War on Cartels: Historic Terrorist Designations Reshape Sanctions Compliance Risks

On February 20, 2025, the U.S. Departments of State and the Treasury designated eight Latin American drug trafficking cartels as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs), in...more

A Minefield in Russia’s Energy Sector: Biden’s Final Sanctions Act May be Game-Changing

Days before President Biden leaves the White House, the U.S. government has delivered a major blow against Russia. On January 10, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced...more

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