Throughout his presidency, President Trump has used tariffs – and the threat of tariffs – to address an unprecedented variety of economic and national security threats. As if to underscore the point, on December 2, 2019, the...more
12/5/2019
/ Agricultural Sector ,
Aluminum Sales ,
Argentina ,
Brazil ,
China ,
Countervailing Duties ,
Country of Origin ,
Customs and Border Protection ,
Digital Services Tax ,
Duties ,
Exports ,
Foreign Trade Regulations ,
Foreign Trade Zones ,
France ,
Imports ,
International Emergency Economic Powers Act (IEEPA) ,
Manufacturers ,
Mexico ,
Requests for Exclusion ,
Risk Assessment ,
Risk Management ,
Secretary of Commerce ,
Section 232 ,
Section 301 ,
Steel Industry ,
Supply Chain ,
Tariff Classifications ,
Tariffs ,
Trade Act of 1974 ,
Trade Expansion Act of 1962 ,
Trade Wars ,
Trump Administration ,
US Trade Policies ,
USTR ,
WTO
On August 5, 2019, the President signed a new executive order ( “EO 13884”) that imposes blocking sanctions on the Government of Venezuela (“GOV”). EO 13884 does not impose a trade embargo or broadly prohibit transactions...more
The U.S. State and Treasury Departments announced that a second round of sanctions will be imposed against Russia pursuant to the Chemical and Biological Weapons Control Act of 1991 (“CBW Act”). The most notable new measure...more
8/7/2019
/ Bank of Russia ,
Biological-Weapons ,
Bond Markets ,
Broker-Dealer ,
CBW Act ,
Chemical Weapons ,
Commodities Traders ,
Commodity Futures Contracts ,
Economic Sanctions ,
Financial Institutions ,
Foreign Banks ,
International Banks ,
Investment Companies ,
National Security ,
Open General Export Licences (OGELs) ,
Russia ,
Secondary Sanctions ,
Trump Administration ,
U.S. Treasury ,
US State Departments
On February 1, 2019, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued guidance in the form of Frequently Asked Questions (“FAQs”) relating to sanctions imposed on January 28, 2019 against...more
2/4/2019
/ Blocked Person ,
Bonds ,
Derivatives ,
Due Diligence ,
Economic Sanctions ,
General Licenses ,
Non U.S. Person ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
SDN List ,
Trump Administration ,
U.S. Treasury ,
Venezuela ,
Winding Down
On January 28, 2019, the United States imposed blocking sanctions on Petróleos de Venezuela SA (“PdVSA”), the Venezuelan state-owned oil company. The measures follow President Trump’s recent decision to recognize Juan Guaidó,...more
1/31/2019
/ Blocked Person ,
Economic Sanctions ,
Energy Sector ,
Executive Orders ,
Financial Institutions ,
Foreign Investment ,
Imports ,
International Emergency Economic Powers Act (IEEPA) ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Presidential Elections ,
SDN List ,
Trump Administration ,
Venezuela ,
Winding Down
On November 5, 2018, applicable wind-down periods for certain transactions with Iran ended and the second and final set of U.S. secondary sanctions that had been lifted pursuant to the Iran nuclear deal – the Joint...more
11/7/2018
/ Blocking Statutes ,
Economic Sanctions ,
Energy Sector ,
EU ,
Exports ,
FinCEN ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
Petroleum ,
SDN List ,
Secondary Sanctions ,
Shipping ,
Special Purpose Vehicles ,
Trump Administration
As expected, following his May 8, 2018, decision to withdraw the United States from the Joint Comprehensive Plan of Action (“JCPOA”), President Trump signed a new Executive Order (“E.O.”) on August 6, 2018, formally...more
8/9/2018
/ Blocking Statutes ,
EU ,
Executive Orders ,
Financial Institutions ,
International Relations ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Nuclear Power ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Secondary Sanctions ,
Trump Administration ,
Winding Down ,
Withdrawal
Following the U.S. decision to withdraw from the Joint Comprehensive Plan of Action (JCPOA) and reimpose sanctions on Iran, the EU has confirmed its full commitment to keep the agreement alive for the remaining parties, as...more
6/13/2018
/ Blocking Statutes ,
EU ,
European Commission ,
Exemptions ,
Foreign Relations ,
General Licenses ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Sanction Violations ,
Secondary Sanctions ,
Trade Relations ,
Trump Administration ,
Waivers ,
WTO
President Trump announced today, May 8, 2018, that the United States would withdraw from the Joint Comprehensive Plan of Action (“JCPOA”), the Iran nuclear deal implemented in January 2016. In connection with the...more