News & Analysis as of

Office of Foreign Assets Control (OFAC) National Security Executive Orders

BakerHostetler

DOJ Implements Bulk Personal Data Transfer Restrictions

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The Data Security Program (DSP) recently implemented by the U.S. Department of Justice (DOJ) will have far-reaching implications for many businesses that transfer the personal data of U.S. citizens outside the United States....more

Miller Canfield

DOJ Rule Restricting Sensitive Data Transfers Takes Effect

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Today, April 8, 2025, the U.S. Department of Justice’s Final Rule restricting transfers of bulk sensitive personal data and U.S. government-related data becomes effective, implementing former President Biden’s Executive Order...more

Paul Hastings LLP

New US Sanctions and Ongoing OFAC Designations Enable the New Administration’s Policy Priorities

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Policy change in Washington since the change in administration has been swift, dramatic in many areas and executed with unprecedented pace. One area, however, has been relatively stable in the administration’s first two...more

K2 Integrity

Escalation Against Cartels: U.S. Designates International Cartels as Foreign Terrorist Organizations and Specially Designated...

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On 20 February 2025, the United States (U.S.) Department of State designated eight international cartels as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs). The designation of...more

Latham & Watkins LLP

Trump Administration Targets Cartels With First Wave of Terrorism Designations

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The designations expand US tools and jurisdictional reach, and raise the stakes for foreign financial institutions and non-US companies to avoid dealing with designated entities....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

Holland & Knight LLP

Trump Administration Announces Designation of International Cartels

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U.S. President Donald Trump issued Executive Order 14157 (the EO) on Jan. 20, 2025, calling for the designation of drug cartels and other foreign organizations as foreign terrorist organizations (FTOs) or specially designated...more

Hogan Lovells

U.S. State Department reinstates Cuba Restricted List

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The U.S. Department of State has formally republished the Cuba Restricted List, restoring prohibitions on direct financial transactions with numerous Cuban military, intelligence, and security-linked entities. This move...more

White & Case LLP

DOJ Implements Major Changes to National Security Priorities

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On February 5, 2025, President Trump's nominee to lead the Justice Department (the "Department"), Pamela Bondi, was confirmed by the Senate to serve as the U.S. Attorney General. Bondi immediately took action to reshape the...more

Bracewell LLP

Guiding Your Company Through Trump’s New Latin America Enforcement Policy

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Shortly after President Trump’s second inauguration, his executive branch took steps to further one of his signature promises: securing the southern border. While these actions primarily impact immigration laws, several...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

Husch Blackwell LLP

Week Three in Trade – First 100 Days of the New Administration

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We previously covered President Trump’s IEEPA tariffs and the various retaliatory tariff and nontariff countermeasures announced by each country in separate posts. Currently, the Mexico and Canada tariffs have been paused...more

Alston & Bird

President Trump Renews “Maximum Pressure” Approach to Iran

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President Trump issued a new Executive Order renewing a commitment to imposing “maximum pressure” on the Iranian government to “end its nuclear threat, curtail its ballistic missile program, and stop its support for terrorist...more

Akin Gump Strauss Hauer & Feld LLP

Imposing Sanctions on the International Criminal Court (Trump EO Tracker)

Order imposes financial sanctions and visa restrictions against International Criminal Court (ICC) officials and their family members who assisted in targeting America and Israel. Within 60 days of the date of this order, the...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

Holland & Knight LLP

Executive Order: Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global...

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Date Issued: Jan. 20, 2025 This executive order initiates the process of designating certain international cartels as Foreign Terrorist Organizations (FTOs) to address the rise in violence and terror across the western...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

Baker Botts L.L.P.

President Trump Issues Executive Orders Announcing Tariffs on Goods from Canada, Mexico, and China

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Through three Executive Orders signed on February 1, 2025 (collectively, the “Executive Orders”), U.S. President Donald Trump announced significant additional tariffs on imports of goods from Canada, Mexico, and China. The...more

Hogan Lovells

The United States and the United Kingdom impose new sanctions against the Russian energy sector

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New U.S. and UK sanctions target Russia’s energy sector and supporting infrastructure. On January 10, 2025, the United States and the United Kingdom imposed additional sanctions against Russia, with a focus on its energy...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

Venable LLP

Trump Administration Prepares to Levy Novel Tariffs

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As anticipated from campaign promises, on Monday, January 20, President Donald Trump issued an executive order (EO) commencing the process to levy a host of new trade tariffs as part of his "America First Trade Policy." New...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

Designating Cartels And Other Organizations As Foreign Terrorist Organizations And Specially Designated Global Terrorists

This Order declares a national emergency under the International Emergency Economic Powers Act (IEEPA) to designate certain international cartels and other organizations as Foreign Terrorist Organizations or Specially...more

Holland & Knight LLP

Commerce Department: Final Determination of Russia-Backed Cybersecurity, Antivirus Software

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The U.S. Department of Commerce's Office of Information and Communications Technology and Services (OICTS) within the Bureau of Industry and Security (BIS) issued a Final Determination on June 20, 2024, pursuant to Executive...more

BakerHostetler

Key Export Control Developments During the First Quarter of 2024

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The first quarter of 2024 saw numerous developments on the export control front. This report summarizes the key developments and provides links to the relevant Federal Register notices and/or agency announcements....more

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