News & Analysis as of

Foreign Policy Biden Administration

Lowenstein Sandler LLP

Revising Missile Controls Is Necessary to Help Allies and Prevent New Nuclear States

As the presidential transition began in January 2025, President Biden promulgated a new National Security Memorandum (NSM) on missile technology exports to advance “the President’s goals of strengthening allied defense...more

Zuckerman Spaeder LLP

As Priorities Change in Cross-border Criminal Investigations, Potential Targets Must Account for Possible Tolling of Limitations

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As the new administration shifts some criminal enforcement priorities, particularly relating to activities abroad, potential targets of cross-border investigations are re-evaluating their strategies and exposure to...more

Troutman Pepper Locke

Financial Transactions Related to Russian Energy Now Prohibited: Expiration of OFAC ‎General License 8L

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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

Crunched Credit

The Perils of Magical Thinking 

Crunched Credit on

I just finished a book by Richard Overy called The Twilight Years analyzing the dying throes of the exceptionalism of the British Empire (American clerisy, please take note).  There was a fascinating discussion about the...more

Saul Ewing LLP

The Foreign Agents Registration Act: 2024 Year in Review and Outlook for 2025

Saul Ewing LLP on

Executive Summary - We entered 2025 with the world in turmoil, a new American administration in the White House, and various global actors—friends and foes alike—still actively vying for the attention of the American public. ...more

Axinn, Veltrop & Harkrider LLP

Can You Ever Come Back from a Presidential Block? The Latest in the Nippon Steel/U.S. Steel Saga

When former President Biden blocked the acquisition by Nippon Steel of U.S. Steel in January on national security grounds, many assumed that was the end for a transaction that would have combined a Japanese powerhouse company...more

Snell & Wilmer

FARA's Pendulum: Shifts in Foreign Agent Regulation

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On her first day in office, Attorney General Pamela Bondi issued a memorandum signaling a significant shift in the Department of Justice’s (DOJ) approach to Foreign Agents Registration Act (FARA) enforcement. The memorandum...more

Akerman LLP

U.S.-Cuba Policy Whiplash

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The United States has enacted several volatile rounds of Cuba policy changes since the start of this year, as incoming Trump administration officials moved on January 20, 2025, to reverse measures enacted less than a week...more

K&L Gates LLP

Trump 2.0 Executive Orders; Shock and Awe

K&L Gates LLP on

Overview - Since his inauguration on 20 January 2025, President Donald J. Trump has signed dozens of executive orders and presidential memoranda on topics including, but not limited to, energy and the environment;...more

Holland & Knight LLP

Trump Administration Rescinds Certain Actions by the Previous Administration to Ease Cuba Sanctions

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Within hours after taking office on Jan. 20, 2025, U.S. President Donald Trump signed an omnibus executive order revoking 78 executive actions by the previous administration, dating back to 2021. Among them, President Trump...more

Akin Gump Strauss Hauer & Feld LLP

Designation Of Ansar Allah as a Foreign Terrorist Organization (Trump EO Tracker)

Summary This Order re-designates Ansar Allah (also known as the Houthis) a Foreign Terrorist Organization (“FTO”), to be effective within 45 days. The first Trump Administration had previously designated the Houthis as an FTO...more

Akin Gump Strauss Hauer & Feld LLP

Initial Rescissions of Harmful Executive Orders and Actions

The Order rescinds executive orders from the Biden administration that are contrary to the values President Trump has supported in his campaign. The revocations focus on the Covid-19 pandemic, use of diversity, equity &...more

Jenner & Block

Biden Blocks Nippon Steel Deal, but CFIUS Expected to Continue Clearing Japanese Investments in the United States

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On January 3, 2025, US President Joe Biden published an order blocking Nippon Steel’s proposed acquisition of US Steel, citing the Committee on Foreign Investment in the United States’ (CFIUS) finding that the deal would...more

DLA Piper

CBP Proposes Rule that Would Eliminate Section 321 De Minimis Exemption Eligibility for Shipments Subject to Section 301 Tariffs

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In the final days of the Biden administration, US Customs and Border Protection (CBP) issued several notices of proposed rulemaking (NPRM) aimed at restricting use of the “de minimis” imports provisions of Section 321(a)(2)...more

Holland & Knight LLP

U.S. Announces Steps to Ease Cuba Sanctions

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Besides certain expansions on remittances in 2022, the White House, on Jan. 14, 2025, issued a statement announcing President Joe Biden's plans to relax sanctions on Cuba through a series of broad measures aimed at improving...more

Troutman Pepper Locke

A Minefield in Russia’s Energy Sector: Biden’s Final Sanctions Act May be Game-Changing

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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

Eversheds Sutherland (US) LLP

Biden Administration imposes sweeping sanctions against the Russian Energy Sector days ahead of the Trump Transition

On January 10, 2025, the Biden Administration issued a broad sanctions package targeting the Russian energy sector, 10 days in advance of the transition to the incoming Trump Administration. The new sanctions also added two...more

Dorsey & Whitney LLP

Has the CFIUS Process Become Political?

Dorsey & Whitney LLP on

On January 3, President Biden issued the Order Regarding the Proposed Acquisition of United States Steel Corporation by Nippon Steel Corporation (the “Order”)....more

Dorsey & Whitney LLP

Biden Administration Again Expands Sanctions on Russia and Its Third Party Supporters

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As Russia continues its war against Ukraine and Ukraine has itself recently opened a new front by capturing Russian territory in its Kursk region, the United States announced on August 23 its latest tranche of sanctions...more

Mayer Brown

Russia/Ukraine Sanctions Update - Month of August

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US SANCTIONS - US Department of the Treasury Takes Further Action against Russia’s International Supply Chains: On August 23, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the US...more

BakerHostetler

Current State of U.S. Economic Sanctions Imposed in Response to Russia’s Invasion of Ukraine - August 2024 #2

BakerHostetler on

In its continuing response to Russia’s invasion of Ukraine, the U.S. government has deployed a whole-of-government approach to impose sanctions and tighter export controls on Russia. This alert summarizes key economic...more

BakerHostetler

Current State of U.S. Economic Sanctions Imposed in Response to Russia’s Invasion of Ukraine - August 2024

BakerHostetler on

In response to Russia’s invasion of Ukraine, the U.S. government has deployed a whole-of-government approach to impose sanctions and tighter export controls on Russia. This alert summarizes key economic sanctions imposed by...more

The Volkov Law Group

U.S. Sanctions Update as of April 2024

The Volkov Law Group on

U.S. Persons prohibited from transactions with anyone on the OFAC SDN List without a license, regardless of country. Includes entities owned in excess of 50-percent by one or more SDNs (33-percent for select Russian...more

Latham & Watkins LLP

US Treasury Department Issues Notice of Proposed Rulemaking on Implementation of Outbound Investment: 5 Key Takeaways

Latham & Watkins LLP on

The proposed regulations would implement President Biden’s Executive Order that restricts certain outbound investments from the US. On June 21, 2024, the US Department of the Treasury (Treasury) issued a Notice of Proposed...more

Brownstein Hyatt Farber Schreck

Policy Highlights from the First 2024 Presidential Debate

On June 27, President Joe Biden and former President Donald Trump participated in the first of two planned presidential debates. The event took place in Atlanta, Georgia, and was hosted by CNN without an in-person audience....more

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