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National Security Export Controls U.S. Treasury

Foley Hoag LLP - White Collar Law &...

Review of International Trade Enforcement in the U.S., E.U., and UK in 2024 and What to Expect in 2025

This is the final in our 2025 Year in Preview series examining important trends in white collar law and investigations in the coming year. Throughout 2024, enforcement of international trade laws continued to gather pace...more

Wilson Sonsini Goodrich & Rosati

President Trump Issues “America First Investment Policy”

On February 21, 2025, the White House released a memorandum titled, “America First Investment Policy” (the Memorandum). The Memorandum describes how this Administration plans to address U.S. national security risks stemming...more

Jones Day

Mitigating Risk From the Designation of Cartels as FTOs and SDGTs

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The Situation: After President Trump issued an Executive Order ("EO") that creates a process to designate international cartels and other organizations as "Foreign Terrorist Organizations" ("FTOs") or "Specially Designated...more

Holland & Knight LLP

America First Investment Policy

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President Donald Trump on Feb. 21, 2025, issued a National Security Presidential Memorandum (NSPM) titled "America First Investment Policy," outlining the administration's priorities regarding inbound and outbound...more

Fox Rothschild LLP

Update on Outbound U.S. Investment Restrictions and Export Controls

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New U.S. investment and export control measures are shaping how businesses engage with foreign markets, particularly China. From limiting outbound investments to tightening export licenses, these evolving policies from the...more

Seward & Kissel LLP

President Trump Seeks “Maximum Pressure” on Iran Through Expansion of Sanctions Targeting Iran’s Oil Exports

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As has been widely reported, the U.S. policy of “maximum pressure” towards Iran has returned. On February 4, 2025, the Trump administration (the “Administration”) issued a national security memorandum (the “Memorandum”)...more

Seward & Kissel LLP

OFAC Announces Two New Waves of Sanctions Targeting Russia’s Oil Production and Exports, Military-Industrial Base, and Sanctions...

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On January 10 and January 15, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced sweeping sanctions targeting Russia’s oil production and exports, military-industrial base, and other...more

Akin Gump Strauss Hauer & Feld LLP

National Security Presidential Memorandum/NSPM-2 (Trump EO Tracker)

Imposes maximum pressure on the Iranian regime to end its nuclear threat, curtail its ballistic missile program, and stop its support for terrorist groups. Relevant Secretaries are required to impose and enforce sanctions,...more

Kelley Drye & Warren LLP

New Tariffs on Mexico and Canada Delayed by One Month

Today, President Trump reached separate agreements with the leaders of Mexico and Canada to delay implementation of tariffs announced over the weekend and originally set to take effect at 12:01 a.m. tomorrow (February 4). In...more

Foley Hoag LLP

Understanding the U.S.’s New Outbound Investment Rules - January 2025

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Effective in January 2025, the U.S. Department of the Treasury issued a final rule (colloquially known as “Reverse CFIUS”) implementing the Outbound Investment Program, which prohibits U.S. persons from making certain...more

Faegre Drinker Biddle & Reath LLP

Treasury’s Outbound Investment Security Program Focusing on China Is in Effect (for Now)

Treasury’s final rule implementing its outbound investment regime went into effect on January 2, 2025. The final rule implemented Executive Order (E.O.) 14105 of August 9, 2023, which declared a national emergency to address...more

Wilson Sonsini Goodrich & Rosati

All is Fair in Love and Trade War: Valentine's Day Predictions for What Comes Next in U.S. National Security Law

As we head toward Valentine’s Day 2025, everywhere you look, love is all around. Washington, D.C., is no exception—the White House and government agencies seem to be proudly displaying their ardor for changing the country’s...more

Hogan Lovells

“America First Trade Policy” memorandum directs a comprehensive review of U.S. trade policy, suggests potential new tariffs and...

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President Trump’s Day 1 presidential memorandum directs a top-to-bottom review of U.S. trade and economic policy and requests that his Administration provide policy recommendations with respect to: the U.S. trade deficit and...more

Wiley Rein LLP

President Trump Issues “America First” Trade Policy and Previews Additional Tariffs on Canada, Mexico, and China - UPDATED 1/22/25

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This alert was originally published on January 21, 2025, and updated on January 22, 2025, to reflect President Trump’s comments that additional 10% tariffs may be imposed on China on February 1. On January 20, 2025,...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

Katten Muchin Rosenman LLP

OFAC Sanctions Russia's Energy Sector

In an effort to reduce Russian energy revenues being used to fund the war against Ukraine, on January 10, 2025, the United States Department of the Treasury's Office of Foreign Assets Control (OFAC), issued a “determination”...more

K&L Gates LLP

New US Sanctions Target Russia’s Energy Sector

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On 10 January 2025, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a package of new sanctions targeting Russia’s energy sector. In an effort to curtail Russia’s oil revenue and ability...more

Holland & Knight LLP

Outbound Investment Screening Rule Goes into Effect

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The U.S. Department of the Treasury's Final Rule on outbound investment screening went into effect on Jan. 2, 2025. The Final Rule establishes a much-awaited outbound investment screening regime, implementing Executive Order...more

Fox Rothschild LLP

Investments in Chinese Technology Companies Limited by New US Outbound Investment Rule

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U.S. investors interested in investing in advanced Chinese technology companies may now be constrained by the U.S. Government’s first-ever outbound investment rule (Final Rule) which took effect on Jan. 2, 2025. The Final...more

Katten Muchin Rosenman LLP

U.S. Eases Economic Sanctions on Syria

In the aftermath of the overthrow of the Assad government on December 8, 2024, the United States has eased (but has not lifted) its longstanding economic sanctions program against Syria. On January 6, 2025, the U.S....more

Skadden, Arps, Slate, Meagher & Flom LLP

Most AI National Security Regs Likely To Remain in Place Under the Next Administration

With the rapid commercialization of artificial intelligence (AI) technology, the Biden administration has been grappling with its implications, including its potential impact on national security. Several departments have...more

DLA Piper

Treasury Finalizes Rule Restricting US Outbound Investment in China, Including Hong Kong and Macau

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On October 28, 2024, the US Treasury Department announced the Final Outbound Investment Rule implementing President Joe Biden’s August 2023 “Outbound Order” (Executive Order 14105). The Outbound Order and associated Final...more

Lowenstein Sandler LLP

Trade Matters - Lowenstein Sandler's Global Trade & National Security Newsletter - September 19, 2024

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The Department of Commerce’s Bureau of Industry and Security (BIS) recently issued an interim final rule implementing licensing requirements for these emerging technology products for export to all foreign countries. See the...more

Paul Hastings LLP

Statute of Limitations for IEEPA and TWEA Violations Extended to 10 Years, and Additional Sanctions Developments

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Recent legislation, H.R. 815, the National Security Supplemental (“the Act”) – further explained by guidance issued by the U.S. Department of the Treasury Office of Foreign Assets Control (“OFAC”) on July 22, 2024 – has...more

Lowenstein Sandler LLP

Trade Matters - Lowenstein Sandler's Global Trade & National Security Newsletter - JULY 12, 2024

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On June 20, the Department of Commerce’s Bureau of Industry and Security (BIS) for the first time banned a software and cybersecurity company using authority provided by June 2023’s “Protecting Americans’ Sensitive Data from...more

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