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Regulatory Requirements International Emergency Economic Powers Act (IEEPA)

Holland & Knight LLP

U.S. Health Data Affected by New National Security Restrictions on International Data Transfers

Holland & Knight LLP on

Health Insurance Portability and Accountability Act (HIPAA)-covered entities and business associates should be familiar with restrictions on the use or disclosure of protected health information (PHI) under HIPAA rules....more

Husch Blackwell LLP

Customs Clarifies That “In Transit” Exemption Only Applies to Ocean Vessels

Husch Blackwell LLP on

On April 30th, U.S. Customs and Border Protection (“Customs”) clarified in its International Emergency Economic Powers Act Frequently Asked Questions that the “in transit” exemption from reciprocal tariffs provided for in the...more

DLA Piper

Department of Commerce Announces Section 232 Pharmaceutical Investigation

DLA Piper on

The Trump Administration issued a notice on Monday titled, “Notice of Request for Public Comments on Section 232 National Security Investigation of Imports of Pharmaceuticals and Pharmaceutical Ingredients,” which could serve...more

Faegre Drinker Biddle & Reath LLP

Frequently Asked Questions: IEEPA and Section 232

On March 21, 2025, U.S. Customs and Border Protection (CBP) updated its Section 232 FAQs to address the recent expansion of the steel and aluminum derivative lists. We note that the additional FAQs added by CBP are under the...more

Troutman Pepper Locke

OFAC Recordkeeping Requirement Extended to 10 Years

Troutman Pepper Locke on

On March 20, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a final rule extending the recordkeeping requirements under OFAC’s regulations from five years to 10 years. This change...more

Foley & Lardner LLP

What Every Multinational Company Needs to Know About … Criminal Enforcement of Trade, Import, and Tariff Rules: A Growing Risk for...

Foley & Lardner LLP on

In less than 100 days, the Trump administration has implemented a dizzying array of new tariffs, significantly increasing costs and complexity for U.S. importers. The administration is keenly aware that companies operating in...more

Sheppard Mullin Richter & Hampton LLP

Data, Deals, and Diplomacy, Part III: DOJ Issues National Security Final Rule with New Data Compliance Obligations for...

On January 8, 2025, the Department of Justice (“DOJ”) published its final rule addressing Executive Order (E.O.) 14117, “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data...more

Dorsey & Whitney LLP

Justice Issues Final Rule Restricting Transfer of Personal U.S. Data to Countries of Concern, Effective in April 2025

Dorsey & Whitney LLP on

The U.S. Department of Justice (“DOJ”) published its final rule (“Final Rule”) on January 8, 2025, that will prohibit or restrict transfer of certain data of U.S. persons to countries of concern, including to China. The Final...more

King & Spalding

Ten-Year Statute of Limitations for Sanctions Violations Update

King & Spalding on

As discussed in our May 7, 2024 alert, on April 24, 2024, President Biden signed into law a foreign military support package (i.e., H.R. 815), which included a provision doubling the statute of limitations (“SOL”) from five...more

The Volkov Law Group

Congress Extends Sanctions Statute of Limitations And Addresses Other National Security Issues

The Volkov Law Group on

On April 24, 2024, President Biden signed into law a sweeping national security legislative package that included the 21st Century Peace Through Strength Act, which includes measures to promote sanctions and export controls...more

Cadwalader, Wickersham & Taft LLP

U.S. Deploys Pincer Maneuver on Perceived Crypto Abuses

Crypto’s two calling cards, decentralization and anonymity, can lead to abuses, such as money laundering and tax evasion. The U.S. Treasury has long combatted crypto money laundering...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – October 2023 Update

Bass, Berry & Sims PLC on

October saw two major enforcement actions involving Russia. First, three individuals were indicted for facilitating the export of controlled U.S.-origin electronics to Russia. Second, the president of a U.S. steel trading...more

King & Spalding

DOJ Releases Updated Export Control and Sanctions Voluntary Disclosure Policy

King & Spalding on

On December 13, 2019, the Department of Justice (“DOJ”) released an updated Export Control and Sanctions Enforcement Policy for Business Organizations (“Policy”), revising the prior policy governing voluntary self-disclosures...more

Stinson - Government Contracting Matters

New Year, New Voluntary Self-Disclosure Policy for Export Controls and Sanctions

Several years ago, the head of the State Department’s Director of Defense Trade Controls (DDTC) explained that, when a company engaged in substantial exporting makes no voluntary disclosures of export control violations,...more

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