Protection of Critical Infrastructure via LIPA and ICTS
Compliance Perspectives: Sanctions, Data and Vetting Third Parties
ITAR for Facility Security Officers
Podcast - Credit Funds: How Managers Can Avoid and Mitigate ERISA Conflicts
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. ...more
In a sweeping, coordinated effort across federal agencies, the US government has taken a giant leap forward to prevent access to data that could be exploited to the detriment of national security. On February 28, 2024,...more
Key Points - On December 22, 2023, President Biden issued E.O. 14114 “Taking Additional Steps With Respect to the Russian Federation’s Harmful Activities.” Specifically, E.O. 14114, which amends E.O. 14024 and E.O. 14068,...more
After months of speculation, the US government took steps to regulate outbound investment in specific foreign industries of concern. President Biden on August 9, 2023, issued Executive Order 14105 directing the Department of...more
On May 19, 2023, the Biden Administration along with leaders of the Group of Seven (G7), unveiled a new package of sanctions. The G7 leaders released a joint statement reaffirming their commitment to offer “the financial,...more
The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) recently announced several sanctions-related actions, including President Biden’s new Executive Order (E.O.) Imposing Sanctions on Certain Persons...more
The Week in Review delivers the impact and analysis for the public, private, and non-profit sectors from our daily reporting of the evolving global sanctions campaign against Russia. ...more
To counter Russia’s escalating incursions into Ukraine and threats to its sovereignty, the United States has imposed a series of sanctions on Russian and Ukrainian persons and interests, to be implemented by the U.S....more
President Biden has signed an Executive Order effective August 2, 2021, affirming and expanding U.S. policy restricting the purchase and sale of publicly traded securities of listed Chinese companies with a nexus to China's...more
ACI’s premier conference “Ensuring Compliance with U.S. and China Economic Sanctions” will take place on September 2021 (EDT) in a virtual format. On November 12, 2020, President Trump signed Executive Order 13959...more
On June 3, 2021, President Biden signed Executive Order 14032 (Addressing the Threat from Securities Investments That Finance Certain Companies of the People's Republic of China), modifying the prohibitions placed by the...more
The new executive order continues the policy of prohibiting US persons’ transactions in the publicly traded securities of select Chinese companies, but expands the scope to include both Chinese companies that operate or have...more
On June 3, 2021, President Biden issued Executive Order 14032 (Addressing the Threat from Securities Investments that Finance Certain Companies of the People’s Republic of China) (“CMIC EO”) that modifies the Trump-era...more
The U.S. government officially removed Chinese smartphone maker Xiaomi Corp. from its blacklist, ending the Trump-era ban prohibiting Americans from investing in the company. In their joint filing in the U.S. District Court...more
On March 12, 2021, a U.S. district court granted a temporary injunction requested by the Hong Kong-listed, Chinese electronics giant, Xiaomi Corporation (“Xiaomi”). The injunction blocks the U.S. Department of Defense (“DoD”)...more
As a preface to this blog, I recently gave a presentation with Nate Picarsic and Emily de la Bruyere at the American Bar Association Public Contract Law Section Fall Procurement Symposium on “China’s Military-Civil Fusion...more
The new Executive Order (EO or the Order) bans transactions by US persons in publicly traded securities of companies identified as “Chinese military companies,” and includes a ban on trading in derivatives of those securities...more
A Presidential executive order was issued on November 12, 2020 finding that “the People’s Republic of China (“PRC”) is increasingly exploiting United States capital to resource and to enable the development and modernization...more
President Trump issued an Executive Order on November 12, 2020 that will prohibit U.S. persons from investing in publicly traded securities of certain companies determined to be affiliated with China’s military. Executive...more
On New Year’s Eve, a federal court relieved ExxonMobil of a $2 million fine levied against the company by the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”). OFAC imposed the penalty against Exxon for...more
• $2 million penalty against Exxon overturned • Court concluded that OFAC failed to provide clear notice of violative conduct • Companies are at risk when acting in context of ambiguous agency guidance At the end of...more
On 10 January 2020, in response to missile attacks by the Iranian military targeting two U.S. bases in Iraq, the United States Department of the Treasury, Office of Foreign Assets Control (OFAC) designated a number of senior...more
Under this new evaluation process, Commerce can prohibit companies from engaging in a wide variety of transactions and order them to cease using the information technology or telecommunication system in question even if it is...more
On October 22, 2019, the Office of Foreign Assets Control (OFAC) issued General License No. 2G authorizing U.S. persons to engage in transactions involving nine companies: Belarusian Oil Trade House, Belneftekhim,...more
• Virtually all transactions with government prohibited • Most transactions with private sector parties still permitted • Practical challenges make Venezuela transactions difficult, including for non-U.S. parties On...more