On May 23, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Syria General License 25 (GL 25), effectively lifting most sanctions imposed under the Syrian Sanctions Regulations (SSR) (31...more
On May 12, President Trump issued an executive order, “Modifying Reciprocal Tariff Rates to Reflect Discussions with the People’s Republic of China” (the Order), temporarily lowering reciprocal tariffs on Chinese imports that...more
5/15/2025
/ China ,
Customs and Border Protection ,
Executive Orders ,
Foreign Policy ,
Foreign Relations ,
Imports ,
order ,
Retaliatory Tariffs ,
Section 301 ,
Tariffs ,
Trade Relations ,
Trump Administration ,
US Trade Policies
On April 17, the Office of the United States Trade Representative (USTR) announced proposed trade actions under Section 301 of the Trade Act of 1974 (Trade Act) to counteract China’s systemic dominance in the maritime,...more
4/23/2025
/ China ,
Economic Sanctions ,
Foreign Policy ,
Foreign Relations ,
Liquid Natural Gas ,
Maritime Transport ,
National Security ,
Ports ,
Section 301 ,
Shipping ,
Supply Chain ,
Tariffs ,
Trade Policy ,
Trump Administration ,
USTR ,
Vessels
On April 11, the White House released a Presidential Memorandum, “Clarification of Exceptions Under Executive Order 14257 of April 2, 2025, as Amended,” which exempts a list of semiconductors and electronics from reciprocal...more
4/16/2025
/ Cell Phones ,
China ,
Critical Infrastructure Sectors ,
Executive Orders ,
Foreign Policy ,
Foreign Relations ,
Imports ,
Innovative Technology ,
Regulatory Reform ,
Semiconductors ,
Suppliers ,
Supply Chain ,
Tariffs ,
Trump Administration ,
U.S. Commerce Department ,
US Trade Policies ,
Wireless Technology
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
4/14/2025
/ China ,
Executive Orders ,
Exports ,
Foreign Policy ,
Foreign Relations ,
Imports ,
Retaliatory Tariffs ,
Tariffs ,
Trade Relations ,
Trade Wars ,
Trump Administration ,
US Trade Policies
On April 2, President Trump declared “Liberation Day” and unveiled a series of sweeping tariff measures aimed at addressing trade imbalances and foreign trade practices while boosting domestic manufacturing. Marking the...more
4/8/2025
/ Canada ,
China ,
Executive Orders ,
Foreign Policy ,
Foreign Relations ,
Goods or Services ,
Harmonized Tariff Schedule of the United States (HTSUS) ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Mexico ,
Popular ,
Retaliatory Tariffs ,
Supply Chain ,
Tariffs ,
Trump Administration ,
United States-Mexico-Canada Agreement (USMCA) ,
US Trade Policies
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
3/28/2025
/ Artificial Intelligence ,
Bureau of Industry and Security (BIS) ,
China ,
Corporate Counsel ,
Economic Sanctions ,
Enforcement Actions ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Policy ,
Foreign Relations ,
Machine Learning ,
National Security ,
Regulatory Reform ,
Technology Sector ,
Trump Administration ,
U.S. Commerce Department ,
US Trade Policies
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
3/28/2025
/ Corporate Counsel ,
Economic Sanctions ,
Executive Orders ,
Foreign Policy ,
Foreign Relations ,
Infrastructure ,
Mexico ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Regulatory Oversight ,
Secondary Sanctions ,
Secretary of Commerce ,
Tariffs ,
Trump Administration ,
U.S. Commerce Department ,
United States-Mexico-Canada Agreement (USMCA) ,
US Trade Policies ,
Venezuela
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
3/14/2025
/ Banks ,
Biden Administration ,
Biofuel ,
Economic Sanctions ,
Financial Transactions ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Natural Gas ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Popular ,
Prohibited Transactions ,
Russia ,
SDN List ,
Secondary Sanctions ,
Trump Administration ,
U.S. Treasury
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
3/11/2025
/ Economic Sanctions ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Popular ,
Regulatory Reform ,
Russia ,
Terrorist Organizations ,
Trump Administration ,
U.S. Treasury ,
US Trade Policies ,
Venezuela ,
Yemen
Last week consisted of many developments surrounding President Trump's tariff policy. On March 4, his sweeping new tariffs took effect, significantly altering the trade landscape for businesses engaged in international...more
3/10/2025
/ Canada ,
China ,
Executive Orders ,
Exports ,
Foreign Policy ,
Foreign Trade Regulations ,
Goods or Services ,
Imports ,
Infrastructure ,
International Emergency Economic Powers Act (IEEPA) ,
Mexico ,
Popular ,
Retaliatory Tariffs ,
Supply Chain ,
Tariffs ,
Trade Relations ,
Trump Administration ,
United States-Mexico-Canada Agreement (USMCA) ,
US Trade Policies
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
2/25/2025
/ Anti-Terrorism Financing ,
Cartels ,
Cooperative Compliance Regime ,
Criminal Prosecution ,
Economic Sanctions ,
Enforcement Actions ,
Financial Crimes ,
Foreign Policy ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Sanction Violations ,
SDN List ,
Terrorist Financing Regulations ,
Trafficking ,
Trump Administration
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
1/17/2025
/ Biden Administration ,
Economic Sanctions ,
Energy Sector ,
Export Controls ,
Foreign Policy ,
Infrastructure ,
Liquid Natural Gas ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Russia ,
SDN List ,
U.S. Treasury
On December 18, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) 1B (Authorizing Certain Activities Involving Federal State Budgetary Institution Marine Rescue...more
1/9/2025
/ Blocked Person ,
Compliance ,
Economic Sanctions ,
Energy Sector ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Regulatory Requirements ,
Russia ,
SDN List ,
U.S. Treasury
On November 27, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) sanctioned 21 high-ranking Venezuelan officials aligned with Nicolás Maduro. These sanctions, issued under Executive Order...more
U.S. sanctions laws present complex conflicts with state insurance laws. While state laws govern the timely payment of claims and other insurance practices, U.S. sanctions administered by the U.S. Department of the Treasury’s...more
On November 7, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License (“GL”) 5Q ("Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5...more
On November 21, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated Gazprombank, over 50 internationally connected Russian banks, more than 40 Russian securities registrars, and 15...more
On October 10, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued Frequently Asked Question (“FAQ”) 1197 on securities held at the National Settlement Depository (“NSD”) in connection...more
On October 9, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued its first-ever guidance to financial institutions (“FIs”) on best practices to comply with the Export Administration...more
On September 24, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued three frequently asked questions (“FAQs”) that provide guidance to U.S. companies regarding the Determination...more
Russian Political Disinformation Efforts -
On September 4, 2024, the U.S. Department of the Treasury's Office of Foreign Assets Control (“OFAC”) designated 10 individuals and two entities as specially designated nationals...more
Iran and Syria Sanctions and Embargos On September 11, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued updated guidance to remind maritime support service providers that the...more
9/25/2024
/ Economic Sanctions ,
Embargo ,
Financial Institutions ,
Foreign Policy ,
Foreign Relations ,
Iran ,
Iran Sanctions ,
ITSR ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Syria
On August 14, 2024, the U.S. Department of Commerce's Bureau of Industry and Security (“BIS”) issued guidance to the U.S. academic community regarding compliance with export controls and to protect U.S. national security....more
On September 5, 2024, the Department of the Treasury's Office of Foreign Assets Control (“OFAC”) released General License (“GL”) 108 (“Authorizing Limited Safety and Environmental Transactions Involving Certain Blocked...more