News & Analysis as of

Foreign Policy Compliance

Thomas Fox - Compliance Evangelist

Regulatory Ramblings: Episode 68 - Why Geopolitical Risk Matters to Compliance and Legal Staff with Mark Nuttal and Chad Olsen

The hasty U.S. withdrawal from Afghanistan in August 2021 under the Biden administration—and the fallout that followed—along with the Russian invasion of Ukraine in February 2022 and the ongoing war, have created inflationary...more

IR Global

Tariff Engineering: A Roadmap for U.S. Importers Facing New Challenges

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You don’t have to be much of a visionary to see the future with respect to importations of merchandise into the United States. President Trump has made it very clear that he plans to use tariff assessments as part of his...more

Mayer Brown

UK Weekly Sanctions Update - Week of March 10, 2025

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AT A GLANCE - In this weekly update, we summarise the most notable updates in the UK sanctions world. If you have any questions in respect of any of the developments set out below, please do not hesitate to contact a...more

Wiley Rein LLP

Sens. Grassley and Peters Introduce Foreign Agents Transparency Act to Enable DOJ to Require Retroactive FARA Registration

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On March 13, 2024, Senator Chuck Grassley (R-IA), Chairman of the Senate Judiciary Committee, and Senator Gary Peters (D-MI), Ranking Member of the Homeland Security and Governmental Affairs Committee, introduced the Foreign...more

Wiley Rein LLP

Congress’ Continued Focus on the Administration and Enforcement of FARA in the 119th Congress

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On March 6, 2025, Senator Chuck Grassley (R-IA), Chairman of the Senate Judiciary Committee, and Senator Gary Peters (D-MI), Ranking Member of the Homeland Security and Governmental Affairs Committee, reintroduced the...more

Morrison & Foerster LLP

America First Investment Policy – Trump Administration Unveils Foreign Investment Strategy

On February 21, 2025, President Trump published a National Security Presidential Memorandum outlining his administration’s views on foreign investment and substantial changes to current regulatory regimes. The...more

DLA Piper

Trump Administration Designates Eight Transnational Organizations as Foreign Terrorist Organizations and Specially Designated...

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Effective February 20, 2025, the Secretary of State designated eight Latin American organizations as Foreign Terrorist Organizations (FTOs) under Section 219 of the Immigration and Nationality Act (INA) and as Specially...more

Vinson & Elkins LLP

Future of FCPA Enforcement Uncertain (For Now) as New Administration Revamps the Law Enforcement Toolkit

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Among the drumbeats of rapid pronouncements and policy shifts since January 20, 2025, the Trump Administration recently issued a 180-day pause on new investigations and enforcement actions involving the U.S. Foreign Corrupt...more

Proskauer Rose LLP

Back to the Future: Protection of Foreign Affairs Focus for FCPA Enforcement

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Under the guise of protecting the President’s authority to conduct foreign affairs, on February 10, 2025, President Donald J. Trump signed an Executive Order pausing enforcement of the U.S. Foreign Corrupt Practices Act...more

Hogan Lovells

Criminal FCPA enforcement paused. Now what?

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On February 10, 2025, President Trump ordered the U.S. Department of Justice (DOJ) to pause enforcement of the Foreign Corrupt Practices Act (FCPA) and issue new enforcement guidelines that take into consideration U.S....more

Woods Rogers

Designating Cartels as Terrorists: Potential Impact on U.S. Businesses

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On his first day in office, President Trump signed an executive order (EO 14157) that sets in motion the designation of certain cartels and transnational crime gangs as terrorist organizations. The President declared a...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

Hogan Lovells

OFAC takes the position that certain kinds of SDN participation in public conferences is not a prohibited service under U.S....

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The U.S. Department of Treasury’s Office of Foreign Assets Control issued a formal guidance letter stating that certain kinds of Specially Designated Nationals could speak at a public conference to share their individual...more

Baker Botts L.L.P.

Compliance, Enforcement, and Litigation Risk Considerations from President Trump’s Executive Order on Designating New Foreign...

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On January 20, 2025, President Trump issued an executive order titled “Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists.” The order directs the...more

The Volkov Law Group

Haas Automation Fined $2.5 Million for Export Control and Sanctions Violations Involving China and Russia

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In one of the first enforcement actions of 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final order against Haas Automation, Inc., a leading manufacturer of computer numerical...more

Akin Gump Strauss Hauer & Feld LLP

Geneva Insights - February 2025

International Geneva – A global governance ecosystem of over 40 international organizations, 178 country representations and 700+ non-governmental organizations....more

American Conference Institute (ACI)

[Webinar] Virtual Passport to Proficiency in Economic Sanctions - March 4th - 27th, 1:30 pm - 4:30 pm EST

ACI’s virtual Passport to Proficiency Economic Sanctions features 21 hours of in-depth training led by a distinguished faculty of sanctions experts, drawn from diverse industries, the virtual event will provide in-depth...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

Holland & Knight LLP

Trump 2.0: Will This Administration Ratify Montreal Protocol 2014?

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In January 2017, Holland & Knight wrote about whether the first Trump Administration would sign and ratify the Protocol to Amend the Convention on Offences and Certain Other Acts Committed on Board Aircraft, known as Montreal...more

Nossaman LLP

U.S. DOJ Proposes FARA Amendments to Narrow Exemptions for Commercial Lobbying

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Background On Thursday, January 2, 2025, the U.S. Department of Justice (DOJ) published a notice of proposed rulemaking (NPRM) in the Federal Register to amend and clarify the Foreign Agents Registration Act (FARA), starting...more

K&L Gates LLP

Article 8a "Best Efforts" Explained

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On 24 June 2024, the European Union (EU) implemented its 14th package of sanctions against Russia to combat its continued aggression against Ukraine. The package introduced new anti-circumvention measures to strengthen...more

Morgan Lewis

DOJ’s Latest Attempt at Modernizing FARA Signals Greater Focus on Compliance and Enforcement

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Following a decade of increased enforcement of what has been considered an oft-confusing law, the Department of Justice recently published a Notice of Proposed Rulemaking proposing several changes to regulations implemented...more

Troutman Pepper Locke

OFAC's Latest General Licenses and FAQs Related to Russian Sanctions

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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

PilieroMazza PLLC

ITAR Registration Fees Increase, Preparing Government Contractors for Financial Impact and Registration Requirements

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On December 10, 2024, the U.S. State Department published a Final Rule, announcing an increase in registration fees with the Directorate of Defense Trade Controls (DDTC), as required by the International Traffic in Arms...more

The Volkov Law Group

American Life Insurance Company Settles with OFAC for $178,421 Related to Apparent Violations of Iranian Transactions and...

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) recently settled with American Life Insurance Company (“ALICO”), a Delaware-based subsidiary of MetLife, Inc., for $178,421, addressing apparent...more

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