On March 6, 2024, the US Departments of Commerce (“Commerce”), Treasury (“Treasury”), and Justice (“DOJ”) released their latest Tri-Seal Compliance Note (“Note”), which focuses on the “Obligations of foreign-based persons to...more
3/14/2024
/ Department of Justice (DOJ) ,
Economic Sanctions ,
Export Controls ,
Extraterritoriality Rules ,
Foreign Relations ,
International Emergency Economic Powers Act (IEEPA) ,
Office of Foreign Assets Control (OFAC) ,
Self-Disclosure Requirements ,
U.S. Commerce Department ,
U.S. Treasury ,
US Trade Policies
I. US SANCTIONS -
US Department of the Treasury Sanctions Almost 300 Individuals and Entities: On February 23, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned almost 300 individuals...more
3/1/2024
/ Asset Freeze ,
Bureau of Industry and Security (BIS) ,
Compliance ,
Economic Sanctions ,
Entity List ,
EU ,
European Commission ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Foreign Policy ,
Imports ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
U.S. Treasury ,
UK ,
Ukraine
Following the invasion of Ukraine by Russia on February 24, 2022, the United States ("US"), the European Union ("EU"), and the United Kingdom ("UK") adopted—together with their allies—successive waves of sanctions, in an...more
2/28/2024
/ Critical Infrastructure Sectors ,
Economic Sanctions ,
Entity List ,
EU ,
Export Controls ,
Foreign Policy ,
Foreign Relations ,
Foreign Trade Regulations ,
General Licenses ,
Military Conflict ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
UK ,
Ukraine ,
Vladimir Putin ,
White Collar Crimes
On January 29, 2024, the US Department of Commerce’s Bureau of Industry and Security (the “Department”) issued a notice of proposed rulemaking seeking comment on a proposed regulation in response to the Executive Order (E.O.)...more
2/15/2024
/ Artificial Intelligence ,
Bureau of Industry and Security (BIS) ,
Cloud Computing ,
Comment Period ,
Customer Identification Program (CIP) ,
Cybersecurity ,
Executive Orders ,
Financial Institutions ,
IaaS ,
Machine Learning ,
National Security ,
NPRM ,
Proposed Regulation ,
U.S. Commerce Department
China made significant changes to the country’s export control rules in 2023, imposing new controls and modifying existing controls across multiple industries and technical areas. As discussed in our prior Legal Update (China...more
On January 16, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) announced important updates to its Voluntary Self-Disclosure (“VSD”) process in a memorandum addressed to all export enforcement...more
On December 12, 2023, the US House Select Committee on the Chinese Communist Party (CCP) (“Select Committee”) released a report titled “Reset, Prevent, Build: A Strategy to Win America’s Economic Competition with the Chinese...more
12/22/2023
/ CFIUS ,
China ,
Economic Sanctions ,
Exports ,
FIRRMA ,
Foreign Policy ,
Human Rights ,
Imports ,
Investment ,
Supply Chain ,
Trade Relations ,
US Trade Policies
A new executive order (the “EO”) signed by President Biden on June 3, 2021, amends existing prohibitions on US investments in companies that the US government has determined support the military of the People’s Republic of...more
6/10/2021
/ American Depository Receipts (ADRs) ,
Biden Administration ,
China ,
Economic Sanctions ,
Executive Orders ,
Foreign Policy ,
Human Rights ,
Investment ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Securities Transactions