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Walking the Tightrope: EU’s Sanctions Enforcement Directive Puts Violators on Notice

In a bold move to tighten its sanctions enforcement, the EU rolled out Directive 2024/1226, establishing minimum rules for defining criminal offenses and penalties related to the violation of EU sanctions. Effective May 19,...more

E(U)xterritoriality of EU Sanctions: The No Russia Clause

The EU is going extraterritorial, and it is doing so through private contract. It is a pretty neat trick. As a general rule, EU regulations do not apply extraterritorially. This policy is a bit pointed, intended to stand...more

Protective Packaging: The EU’s Economic Security Package Changes the Landscape in Global Technology Controls

The EU plans to step up controls on its home grown technology. That is the short version. The longer version is a (pretty dry) recitation of the proposed legislation and whitepapers that were published last week as the...more

The EU’s 11th Sanctions Package: The Long(er) Arm of the Law

On June 23, 2023, the EU released its 11th package of sanctions on Russia. This package is designed to improve enforcement with new anti-circumvention rules, new trade restrictions, and new designations. The...more

Friday Development: New Sanctions and Export Controls to Address Russia’s Ongoing Aggression in Ukraine (Including the use of...

In response to Russia’s ongoing aggression in Ukraine, both the United States and the European Union have imposed additional sanctions and further restricted exports to Russia and Iran. These new controls span many...more

Tightening the Cordon – U.S. Restricts Licensing Policy and Adds Allies to Technology Controls

On Monday, February 13, 2023, the U.S. government will officially issue a stricter policy of denial for providing lower-tech items to Huawei. Technological containment continues as the Netherlands and Japan move to impose...more

Myanmar Sanctions – A Last Resort Against a Non-Cooperating Country

On October 21, 2022, the Financial Action Task Force (FATF) officially moved Myanmar onto the agency’s blacklist, where it joins Iran and North Korea, the only other two listed countries. It is likely that the United States...more

U.S. and Allies Impose Additional Severe Costs on Russia for Atrocities in Ukraine (update)

Updated as of April 12, 2022 - It has now been more than 40 days since the start of Putin’s brutal invasion of Ukraine. Today, following the recent revelations of the atrocities committed in Bucha, Ukraine by Russian armed...more

Russian Risk: Transactions with Russian Banks and Exports to Russia Create Greatest Exposure Under New U.S. Ukraine-Related...

Updated as of February 25, 2022 - Key Takeaways of OFAC (Treasury) and BIS (Commerce) Actions - Major Russian Banks Blocked from the U.S. Financial System. Six major Russian banks — VEB, Promsvyazbank (PSB), VTB Bank,...more

Russian Risk: Transactions with Russian Banks and Exports to Russia Create Greatest Exposure Under New EU and UK Ukraine-Related...

Updated as of February 25, 2022 - Key Takeaways of EU and UK Recent Actions Against Russia and Ukraine Breakaway Regions - The EU adopted the first tranche of sanctions restrictions targeting financial institutions, other...more

U.S., UK and EU Sanctions Over Putin’s Recognition of Breakaway Ukraine Regions

U.S. Comprehensive Sanctions Against the DNR and the LNR - Scope: the DNR and LNR - The new EO does not detail which parts of the Donetsk and Luhansk regions[1] are subject to the new U.S. sanctions. It is likely that...more

Arming for a Trade War: The EU Proposes an Unprecedented Anti-Coercion Regulation

Scope of the Proposed Regulation - The Regulation would apply where a third country interferes in the legitimate sovereign choices of the Union or a Member State, by applying or threatening to apply measures affecting...more

EU Bans Whitening Food Additive E171 as of January 1, 2022

Starting January 1, 2022, the use of E171 titanium dioxide as a food additive will be banned in Europe. The European Commission’s proposal to ban E171 in food products throughout the European Union was approved a few weeks...more

A Ruble Without a Cause: What Economic Sanctions on Russia May Mean for Your Business and Global Finance

With Russian forces massing at the Ukrainian border, the U.S. and EU have been warning of severe economic sanctions. While we wait and watch this brinksmanship play out, it is worth considering how businesses, and...more

U.S. Imposes Sanctions Measures Targeting Myanmar Military Government

On February 1, 2021, the Myanmar military overthrew the country’s democratically elected government and installed an army general as head of state, with a cadre of military officials and their allies running the government. ...more

USTR Suspends Tariffs on Certain French Luxury Goods: A Potential Shift in Trade Talks

Key Takeaways: • Threatened 25% tariffs on French luxury goods are suspended. • USTR is still looking at tariffs in retaliation for taxes on U.S. global tech companies. • Biden’s new USTR will face immense pressure to...more

The Next Four Years in International Business

Over the past few weeks, we have been speculating on the international trends and tides we expect to see in the next four years under a new U.S. presidential administration. So that you can enjoy our prognostications (before...more

Foul Balls and Red Cards: How Baseball and Soccer’s Different Approaches to Cheating Illustrate the Power of Organizational...

This spring, two major sports teams were caught cheating. Both are consistent championship contenders in recent years. In the United States, hardly any sports fan could have missed the report released by Major League...more

Potential Impact of U.S.-France Trade Tension on U.S. Imports of French Products and Luxury Goods

On December 2, 2019, the U.S. Trade Representative (USTR) announced that in response to a digital services tax law passed in France, it would be retaliating with stringent tariffs on luxury products coming from France. The...more

Investments With Borders: CFIUS-Style Foreign Investment Review Goes Global

The Committee on Foreign Investment in the United States, CFIUS, is the U.S. government agency that conducts national security reviews of foreign direct investment in the United States. The CFIUS rules have been significantly...more

Stuck in the Middle With You: EU Blocking Statutes, Iran Sanctions, and the Thousands of Businesses Caught In Between

Imagine telling your company’s Board of Directors that the company will have to knowingly violate the law. Further, you might note, the American Law Institute’s Principles of Corporate Governance state that, with very limited...more

2018 EU Trade, Regulatory and Competition Trends

Our “trends for 2018” are only a selection of interesting developments to watch for in 2018. Within the political and legislative cycle of the European Union, 2018 promises to be an eventful year, given that it is the last...more

CFIUS for Europe? New Screening of Foreign Direct Investments in Europe

On September 13, 2017, the EU Commission released a proposed regulation establishing a framework for screening Foreign Direct Investments (FDI) in Europe. Several EU Member States have already implemented national mechanisms...more

In the Chaos of (Trade) War, Where Does Your Company Find Peace?

On July 27, 2017, the U.S. Congress sent to President Trump’s desk a bill that imposes new financial sanctions against Russia, Iran, and North Korea. It appears nearly certain that the president will sign that bill, now...more

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