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Venezuela Sanctions: Wind-Down of General License 41 and Introduction of ‘Secondary Tariffs’

The dynamic pace of early policymaking by the new U.S. administration has continued into the spring of 2025, including in the context of sanctions on Venezuela. While Venezuela is not, and has not been, subject to...more

Further Sanctions Aim to Sever Remaining Ties Between Russia and U.S. Financial System

On November 21, 2024, the Biden Administration announced sweeping new sanctions targeting numerous Russian banks, financial institutions and officials, including one of the largest remaining unblocked Russian banks,...more

New Emphasis on Human Rights and Human Rights Due Diligence in U.S. Export Controls

As the European Union has made continued progress toward implementing a holistic human rights legislative agenda, the United States, in the wake of the recent second Summit for Democracy, began to push its own set of human...more

New U.S. Semiconductor Technology Controls Impose Strict Burdens, and Sow Confusion

On October 7, 2022, the Commerce Department Bureau of Industry and Security (“BIS”) – the primary gatekeeper on U.S. export controls – unleashed two lengthy and highly complex sets of regulations, aimed squarely at stopping...more

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